SAIM9092 - Deduction of tax: yearly interest: UK source: specialty debt
Debt paid under a deed
Finance Act 2013 amended ITA07/S874 by inserting a new subsection (6A) to provide that in determining whether yearly interest arises in the UK for the purposes of the duty to deduct income tax at source, no account is to be taken of the location of a deed under the terms of which interest is payable. HMRC바카라 사이트檚 view is that the physical location of the deed does not determine the source of the interest, but the amendment puts it beyond doubt that the duty to deduct tax at source applies in cases of what is known as 바카라 사이트榮pecialty debt바카라 사이트� (that is, debt paid under a deed).