Payment of interest overseas - both recipient and payer are outside the UK

A non-resident company has to pay UK-source interest to another non-resident company based in the US. So, in practice, both recipient and payer are resident outside the UK. There is an obligation for the payer to deduct income tax and to account for the tax to HMRC under ITA07/S874 (1) and (2). Can you please provide some guidance how to report and pay the amount to HMRC in practice? This is not explained in the Savings and Investment manual: https://www.gov.uk/hmrc-internal-manuals/savings-and-investment-manual/saim9240

Hi,

You can see guidance here:

Corporation Tax: return of Income Tax on company payments (CT61)

Thank you.

Hi, thank you for your reply. I read the guidelines, but it seems that in order to file the CT61 form, we must be a UK resident company and have a UTR, which is not the case. We are based in Luxembourg and have no presence in the UK, the recipient is based in the US. Is there a way to contact an HMRC officer, provide the information about the interest payment and wait for an assessment of the tax due? Can Art.963, paragraphs 2 and 3 of the ITA07 be applied to our case?

Hi adri_ss,

You can find information about the obligation for companies not resident in the UK to deduct basic-rate income tax from UK-source interest at:
 SAIM9200 - Payment of interest overseas
and
SAIM9090 - Deduction of tax: yearly interest: UK source: the general rule.
If you are unable to request a CT61 return, please write to Business Tax and Customs, HMRC, BX9 1AX. 

Thank you.