Norfolk and Montagu on the Taxation of Interest and Debt Finance

IMPORTANT UPDATE: Norfolk and Montagu on the Taxation of Interest and Debt Finance is now only available online

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

Continually reviewed to ensure that the content is accessible and up to date, the commentary offers unprecedented broad and deep integrated coverage of both the law and accounting practice and as they stand today and have stood in previous years.

The text has also been expanded, in recent years, to offer thematic commentary on the approach taken by the courts to 'deeming' provisions, 'purpose' tests and the meaning of 'payment', providing an unique and invaluable resource for solicitors, barristers, accountants and all tax practitioners whether working 'in house' or in private practice.

Which key topics are covered?
The wide range of topics covered in this text include:
- what constitutes interest
- whether interest is yearly and payable subject to withholding;
- reporting obligations under FATCA and the CRS;
- income tax, capital gains tax and corporation treatment of financing arrangements (including Shari'a arrangements);
- IFRS GAAP and UK GAAP relevant to the corporation tax treatment of financing arrangements;
- the taxation of employment-related and close company loans (including the disguised remuneration rules and the April 2019 loan charge);
P2P lending;
- stamp tax, IHT, CGT and VAT treatment of interest and loans;
- interest on underpaid and overpaid tax;
- the Bank Levy (as rescoped from 1 January 2021) and the Banking Surcharge;
- the taxation of repurchase and stock lending arrangements; and
- HMRC's Code of Practice on Taxation of Banks.

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:
- determining whether interest has a UK source or whether a compensation payment could be subject to withholding tax;
- advising a private client from an income tax, CGT or IHT perspective in relation to a borrowing or debt investment;
- determining whether a financing arrangement is disclosable under DOTAS or DAC 6;
- identifying reporting obligations under FATCA or the CRS
- planning how to raise funds for a particular project or business; and/or
- restructuring the borrowings of a company or a group of companies.

Format: Online
Updated: Four times a year

About the editor
Gerald Montagu leads Gide Loyrette Nouel LLP’s international tax practice in London.

IMPORTANT UPDATE: Norfolk and Montagu on the Taxation of Interest and Debt Finance is now only available online

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Norfolk and Montagu