adri_ss

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?

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