The issue, transfer and redemption of loan notes do not generally give rise to any liability to stamp duty or stamp duty reserve tax. 1 0 obj <>>> endobj 2 0 obj <>stream While we understand the commercial driver for such a feature, it can often create an unexpected tax issue for investors. A loan note is a kind of IOU from one party to another. Would information not be provided to the recipient regarding interest and tax deducted, You really need to start providing all relevant information at the start. Payments of interest that do not 'arise' in the United Kingdom. For further details of the FA15 changes see CFM35985. In addition, for financing transactions, it is important that companies are not considered to be thinly capitalised considering the level of debt versus equity. However, it now transpires that the company has agreed with HMRC that as part of the interest should be deductible in the company accounts the loan note holders can reclaim (reduce the taxable amount) that % which did not qualify for a CT deduction. Payments of interest paid to or by a UK bank (or a UK PE of a foreign bank). Many treaties allow reduced rates for a wider range of royalties. interest accruing prior to 3 December 2014, and. (dZAH6iQB`N2SD#eJSA,m_PAH6NHAH6QIAH6TJF9$F`D#b[YD?+ANEr]nS+96B]FT?+UEr[fm+95FBB`N5T@/sj=+96K`AH6QIDub"\Er[<_E<(+]@/t-E+96?\AH6NHC]J#HD?+bYAH6cOE<(+]AH3hQD?+5J@fRVOD?+)FD#b[Y@/t*DB`N,QFT>hMD#b[YEr]bOD#b[YAH6fP+96K`DZFeXF9$4ZEW@]l+94h1Er^:^+95gMD?+bYAH3hQB`N#N+969ZB`MTBBE0.TD#duEFT?F^B`N2S+95mOFT?F^Er^=_Er[<_D#duEF9$C_B`N2S/c[!o:]P;3@/tBLAH6-=+95pPB`MWCF9$F`D#eVWF9!E`FoZ(REr^:^B`MTBFT?4XFT?7Y+96E^BE2rND?+/HFT?I_+95sQEr^:^+96?\AH6NHC]J#HD?+bYAH6cOE<(+]AH3hQAH6NHB`N5T+96NaC]J8O@/t-E@fUEIEWC%YAH6`N+95pPB`McGD?+ANEr^7]B`MuM/c[!otQ+95sQFThMF9!E`@/sd;+96!RAH6NHB`N2S/c[!o;ZLA/A,m_P@K:3E@/t0FA,pEWC"X+96QbDZFSRFT?L`Dua;HF9!E`Er]bOA,m_P@fUNL@/t?K+96<[EWBtW@/t?N=mBB)l9=1]V"cDua5FDuaqZ/c]G_DuaqZ, 69,921,949,945,text,6ND$)Dub.`EWBeRB)lTFF9!E`W;n%@;ugS3DZFVSEr^+YD?(dZ;?18.FT?L`AH6`NEr[<_6NCNpD?+)FA,p$<+95(8B`MuMB`N5TAH66@+96<[EW@3^B`N5TEr[<_C]J/L@fU'?D?+_XDZFeXEr[fm+94\-C]J8O+96E^B`McGBE3,SEr[<_EWBYNEr]bOEWC7_AH66@/c[!o<<.(?AH3hQDZFAL+954Er]nSF9#kPEr[<_$34K7D?+2ITE'$5AH6`NFoZ4V@fU'?Er[<_B`N2S+96H_FT>kNC&hfF@fUTN+96K`DZCm[F9#tSAH3hQF9#kPEWBqVEr[<_DZFAL+96NaEr]bO+95gMD?+2I+954AH6iQF9#kPEWC.\+95(8AH6?C@/t*D+95=?DZFSRFT?L`B`N&OD? As an alternative to paying the interest, in order to obtain a tax deduction under the late payment rules, it is also possible for the borrower to issue Payment in Kind notes (PIK notes) to the lender. payment was made prior to 1 June 2021 (or 3 March 2021 where anti-abuse measures are applicable) of an amount that would have qualified for exemption under the EU Interest and Royalties Directive prior to Brexit. 131,340,488,866,text,8-!3$@/sgtQ+96QbB`N;VAH6`NEWBMJ+966Y@/tEMEWBeREr[<_B`N#N+95gMC]J/LE<(+]@/t-E+96H_AH6QI/c[!o8HtQ/c[!o70%E0+963XAH6WK+95pPFT?+UEr[<_FT?L`+95pPB`MQAD#b[YE<(+]@/t-E+969ZFT?4XC]IlD+96?\DZFeXF9$C_B`N5TDZFeX/c[!o6i_-*C]JAREW@3^Er]nSF9!E`@/t-EAH6fP+95mODZFYTEr]bO@fUTNAH6fPFT?F^+95gMA,ptQEWBYN/c[!o9`ST%FT?F^B`N2S+969ZFT?:Z@fRVO@fUEID?+;LFT>tQ+969ZB`N2SB`K7UFoZ4VF9#_LAH3hQEr^=_Er]\MB`N)PB`N5T+96K`AH6NHC]JSXEr[fm+94\-A,phMA,p$<+96!R@/t-EAH6cO+95gM@fRVOF9$F`EWC%YB`N2S/c[!o;uh%@EWC%YB`N2S+95sQB)lKCEr^:^@/t?K+96*UD?+bYAH6?CAH6`N+95sQB)lKCF9!E`@/t*DB`N,QFT>tQF9!E`D?+AN@K:'A/c[!o;ugh:EWC1]DZFeX+96QbB`N5T@/sj=+96?\FT?F^FT?I_+96!R@/tEM@fU3C@K:NNEr[<_DZFeXD?+)FEWBYN+96H_FT?I_DuaGLD?+2IB`N2SEr]bO+96H_AH66@+969ZB`N2SB`Kac+95@@B`N#N@fU3CA,p`PD?+bY+96<[EWBtW@/ttQF9!E`D?+AN@K:'A+96?\EWBMJAH6cOAH6TJF9!E`F9$=]B`N2SF9$"TE<(+]AH3hQD#duEB)lfL@/qDMEr]nSF9!E`@/t-EAH6fP+96?\FT?F^FT?I_/c[!o<<.+@+96K`DZFeXF9$4ZEW@3^DuanYAH6fPB`N8UD#b[YFoZ4VFoZ(REWC+[@/qDMEr^=_Er^.ZAH6TJA,ptQ+969ZAH6]MFT>tQ+96$SEWBMJFoZ4VA,p$<+96*UD?(dZAcQBBEWBqVAH6TJF9$F`D#b[YAH6fP+96H_DZFSRC]J/L@fU3CF9$F`A,ptQEWBYN+95gM@fRVOFT?L`+95mODZFYTEr]bOE<(+]@/tBL/c[!o;#k_=B`N2S+95jNC]IlDD?+2IB`N5T+96K`FT?F^DuaSPEr[<_@fUWOEWC.\FT?I_+96*UD? 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