In Andrew Collin Perrin v HMRC (TC03363 – 26 February 2014) the tribunal decided that interest paid by Mr Perrin to an Isle of Man recipient arose in the UK and was therefore subject to a deduction for UK tax (ITA 2007 s 874).
Mr Perrin was UK resident and domiciled. Blackstar was an Isle of Man incorporated company (and the trustee of a retirement benefit scheme of which Mr Perrin was a beneficiary). Under a loan agreement Blackstar made several loans to Mr Perrin making payments from its Isle of Man account to Mr Perrin’s Isle of Man account.
The tribunal first noted that the fact that the agreement was under the jurisdiction of the Isle of Man did not disapply the general rule that the situs of a debt is where the debtor resides as this is where recovery can be enforced. However ...
