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For many international groups this potential withholding tax liability is overridden by the interest article of a UK double tax treaty, if the UK company's lender is resident in a Contracting State. However, this note assumes there is no possibility of treaty or EU Directive reliefs. The most common reason for this is that the lending company is an offshore company, i.e. not registered and resident in an EU member state and not party to a suitable tax treaty with the UK.
In my article, I discuss the implications for UK companies borrowing from overseas lenders following the case of Ardmore Construction Ltd.