Interest payable to overseas investors in UK debt securities is subject to UK withholding tax. Ben Jones and Deepesh Upadhyay examine the four commonly used mitigating routes
The restricted bank lending environment of recent years has resulted in an increase in general and acquisition fund-raising through the issue of corporate bonds loan notes and other similar debt securities.
This shift has coincided with an increase in cash-rich investors from emerging economies and sovereign wealth funds resulting in many such debt securities being held by overseas investors.
Where interest-bearing debt securities are issued by a UK...
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