James Hume (Slaughter and May) examines what’s changed.
As discussed in an earlier article the government announced as part of the 2014 Autumn Statement that it would introduce a new exemption from withholding tax on interest paid on private placements a form of selective direct lending to non-individual borrowers. Legislation providing for that exemption has now been enacted as part of FA 2015 although there is still some way to go before it takes effect.
Draft primary legislation and a technical note were published shortly after the announcement. The draft primary legislation sought to impose five conditions for the exemption to apply. First the interest had to be paid on a security. Secondly that security had to be issued by a company. Thirdly the security had to...
