I am a UK non-resident but have UK earnings and submit a tax return each year. I am a sole shareholder in a EU company. The company cannot get access to UK bank interest very easily but would like to take advantage of the increased rates. The company is prepared to lend me money for me to invest in UK bank deposits, I have to pay the non-resident company equivalent of what the company would get in EUR deposits for an equivalent time-frame + 50% of interest margin between the EUR & UK. This means that I get 50% of interest margin of interest margin between the EUR & UK. Say EUR interest rates is 4%, UK interest rate is 5%, I would have taxable income from interest of 5% and a cost of 4.5% ((4% + (5%-4%)*50%) = Net interest to me of 0.5%. Am I allowed to deduct the full interest cost to me in my UK tax return and so I have taxable income on 0.5% for this transaction? Does HMRC see that interest is paid by me and will only tax the net interest of 0.5% at 10%? not the gross interest of 5% at 10%?