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Posted Thu, 17 Apr 2025 12:44:30 GMT by TANIA Warnock
Do I need to report interest received from a loan note issued by a UK company if I am a UK citizen who is a resident of Qatar and non-resident in the UK?
Posted Thu, 01 May 2025 16:31:10 GMT by HMRC Admin 19 Response
Hi,
You can see guidance here:
Tax on your UK income if you live abroad Contents
Thank you.
Posted Thu, 08 May 2025 14:00:10 GMT by TANIA Warnock
Loan notes are not covered by this guidance which is why I posted the question on the forum.
Posted Thu, 08 May 2025 16:14:55 GMT by Clive Smaldon
Not HMRC, article 11 of the UK/Qatar Double Taxation Agreement...you need to determine if and which paragraphs apply
Posted Mon, 12 May 2025 15:06:58 GMT by TANIA Warnock
Thank you, I had already read the double taxation treaty and it doesn't mention loan notes either. On the subject of interest, it says “The term "interest" as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures.” So, would HMRC consider interest received from a loan note issued by a private company as “income from a debt-claim”? If it would, then the interest rules apply (which I believe are that, as a resident of Qatar, I don't pay tax in the UK on interest arising in the UK).
Posted Tue, 13 May 2025 10:58:43 GMT by HMRC Admin 21 Response
Hi TANIA,
Please refer to: Tax on savings interest as to what is classed as interest for this purpose.
Thank you.
Posted Tue, 13 May 2025 11:07:03 GMT by Clive Smaldon
Yes...its a "loan" note, this is a recognition that you are deemed to have loaned the company capital, and the company recogizing it is in debt to you by the capital amount, and therefore it is paying you interest on that capital debt, it is no different than having a credit balance on an interest earning account with a bank, that bank acknowledges the person has leant them the credit balance and pays them interest on the debt.
Posted Thu, 15 May 2025 05:25:51 GMT by TANIA Warnock
Thank you Mr Smaldon!
Posted Sun, 18 May 2025 07:48:14 GMT by TANIA Warnock
One last thing, if something (like this interest) isn't taxable, do we leave it off the return completely?
Posted Mon, 19 May 2025 16:17:35 GMT by Clive Smaldon
If you are completing a return I'd make reference to it in the "additional information" box...to the effect of "Loan note interest received £xxxx.xx, under UK/Qatar DTA article 11 as it applies to me not liable in the UK"...if thats your position.
Posted Tue, 20 May 2025 13:00:32 GMT by HMRC Admin 17 Response

Hi ,
 
If it is not taxable income you only need to make reference to it in the comments section of the return .

Thank you .

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