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CT61 or not

Loan from Hong Kong individual to a UK Ltd Company

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A Hong Kong Indvidual is lending some funds to a UK compnay with a fixed interest amount and a fixed repayment date.  No monthly payments to be made.

Does the UK Co need to deduct tax and complete a form CT61?

Thanks for your help

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By Matrix
11th Feb 2020 13:03

Per Article 11 of the treaty there is no withholding tax on interest paid to an individual resident in the other state. Whether you need a certificate of residence or a treaty form to be completed to pay the interest without deduction of tax is a matter for further research. You could call the corporation tax helpline and ask for the technical team.

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Replying to Matrix:
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By Matrix
11th Feb 2020 13:14

I couldn’t find a country specific form but you could see if this one applies - call the number in Note 6.

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