Norfolk and Montagu on the Taxation of Interest and Debt Finance
Editor: Gerald Montagu
Consultant Editors: Felicity Cullen QC and Steve Collings
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.
What will forthcoming issues cover?
Issue 33 completes a restructuring of the text which has involved splitting out commentary on applying statutory “deeming” provisions, purpose tests and the meaning of “payment” into a new Chapter 15.
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Consulting commentary on repealed provisions when considering how to respond to a “follower notice”