babyboss88

Hello,
I'm a director and shareholder of a UK limited company ("Company"). I am based in Hong Kong, not a UK tax resident, and provided a shareholders loan to the Company. I am charging interest expenses to the Company based on market rate.
As UK and Hong Kong has double tax treaty arrangement, I am trying to obtain a relief from UK interest withholding tax from HMRC through Form DT Individual.
There are two applications in the form:
(1) For the period that interest withholding tax has not paid by the Company, apply for relief at source from UK interest withholding tax requirement, and
(2) For the period with withholding tax that has been paid by the Company through form CT61, claim refund from HMRC.
There are two submissions of Form DT Individual made, first on late Jun 2024, and later resubmitted on early Sep 2024 with further information provided. There are no feedback on the Form DT Individual submissions until now (22 Oct 2024). I also checked with HMRC hotline but they are unable to locate the form given I do not have NI number that they can be referenced to. I have provided the loan agreement as well as my HK Certificate of Resident Status issued by HK Inland Revenue Department in Form DT Individual submissions.
My question is, given there is no feedback from HMRC in my Form DT Individual submissions and follow up calls with HMRC hotline, and the Company's annual tax return shall be filed soon after Company's year-end, with the supporting of loan agreement and HK Certificate of Resident Status issued by HK Inland Revenue Department, when I file the Company's corporation tax return, can I:
(1) for the period with interest withholding tax that has been paid by the Company, regard as refundable item Due from HMRC in the Company’s balance sheet, and
(2) for the period that interest withholding tax has not been paid by the Company, apply for regarding this as for relief at source from UK interest withholding tax requirement?
Are there any other suggestions on the next steps?
Any direct line or email that I can check with?
Looking forward for your reply.
Regards, babyboss88

Dear Sir / Madam, I would like to check the stamp duty land tax (SDLT) if can claim refund of the 2% non-UK resident surcharge in the following situation: Person A and Person B has set up an UK limited company (Company A) for purchase of UK residential property. Person A and Person B are married. At the time of the purchase: - Person A: holds 50% shareholding of Company A, Person B: holds 50% shareholding of Company A - both Person A and Person B are director of Company A - both Person A and Person B are non-UK tax resident As Company A was under non-UK control, 2% SDLT surcharge was paid by Company A at the time of purchase of the property. Subsequently, within 2 years limit of the purchase, Person A move to UK and becomes UK tax resident. Person A and Person B continued to be married. Shareholding of Company A changes so that: - Person A: holds 51% shareholding of Company A, Person B: holds 49% shareholding of Company A - both Person A and Person B are director of Company A - both Person A becomes UK tax resident, and Person B remain as non-UK tax resident After the above changes, if this can regard Company A now becomes under UK-control, 2% SDLT surcharge paid by Company A at the time of purchase of the property can claim refund? Many thanks. Regards, babyboss88