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Posted Fri, 26 Jan 2024 01:42:19 GMT by
I have an UK limited company, the funding of the business are from my shareholders loan and i'm planning to charge interest on shareholders loan based on market rate. I are based in Hong Kong. Given there is double tax treaty between UK and Hong Kong, for interest expense paid by the Company to shareholders, how to make use of the double tax treaty so that interest paid by the Company to me does not need to pay 20% interest tax in UK? If (Route 1) as the double tax treaty and circumstances is clear, no quarterly CT61 form need to be filled and no 20% interest tax to be paid by the Company, and the Company can update the HMRC on annual tax filing on the details of the details of the arrangement will do? or (Route 2) if one waiver application from quarterly CT61 filing and 20% interest tax need to be applied to HMRC? If need, how to make the waiver application? Or any other suggested routes? Many thanks.
Posted Wed, 31 Jan 2024 14:28:23 GMT by HMRC Admin 13 Response

Thank you for your query.
If you live in a country that has a double taxation treaty with the UK giving relief from UK Income Tax, you can use form DT Individual to apply for the relief at source and claim a repayment of UK Income Tax.
Please see
Double Taxation: Treaty Relief (Form DT-Individual)

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