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Norfolk and Montagu on the Taxation of Interest and Debt Finance

Gerald Montagu, Felicity Cullen QC, and E.C.D. Norfolk

ISBN: 9781845928537

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Publication Date: April 2020

Publisher: Bloomsbury Professional

Law As Stated At: 11 March 2020

Norfolk and Montagu on the Taxation of Interest and Debt Finance

Norfolk and Montagu on the Taxation of Interest and Debt Finance

This leading looseleaf provides an authoritative, pragmatic and accessible guide to the taxation treatment of interest and debt finance for both individuals and companies.

History and context

Taking you back to 1799, it explains how the law and accounting practice in this field have developed, helping you to understand both current practice and the policy rationale which will drive future developments.

Restructured and reissued

Continually reviewed to ensure that the content is accessible and up to date, the text was restructured in 2012 and a second volume was added in July 2014 to accommodate significant recent expansions, such as the addition of a chapter on the taxation treatment of banks.

Which key topics are covered?

The wide range of topics covered in this text include:

    What constitutes interest and whether interest is yearly

  • Withholding tax, the EU Savings Directive and FATCA
  • The taxation of employment related and close company loans (including under the disguised remuneration rules)
  • Stamp tax, IHT, CGT, and VAT treatment of interest and loans
  • The taxation of repurchase and stock lending arrangements

What have recent issues covered?

The most recent issue offered expert commentary on the EU Savings Directive 2014, relevant measures in the Finance Bill and the HMRC April 2014 Technical Note on reforming the loan relationship rules.

When should you consult this resource?

The expert advice within this text is invaluable in a wide range of day-to-day scenarios, such as:

  • Advising a private client from an income tax, CGT or IHT perspective in relation to a borrowing or debt investment
  • Determining whether interest has a United Kingdom source
  • Restructuring the borrowings of a group of companies.
  • Considering whether a compensation payment could be subject to withholding tax
  • Understanding the approach taken by the courts to “deeming” provisions and “purpose” tests.
  • Consulting commentary on repealed provisions when considering how to respond to a “follower notice”.

Up to date to Issue 47, 11 March 2020.