In Hargreaves Property Holdings Ltd v HMRC  UKFTT 390 (TC) the First-tier Tribunal (FTT) determined that certain interest payments had a UK source as the interest was paid by a UK-resident debtor out of its assets situated in, and the profits of activities conducted in, the UK. Having determined that the interest payments had a UK source, the FTT went on to consider whether the interest was “yearly” or “short” in nature. (Under s246 TCA 1997, if a payment of “yearly” interest with an Irish source is made by a company, then the company (or the person through whom the payment is made) must, on making the payment, deduct withholding tax.)
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