Hi all - I would like some guidance on the following as I feel I'm going round in circles:
I have tried online and spoke to HMRC (who were very nice but could not answer questions).
a) Is the Isle of Man a qualifying territory for WHT purposes? ie no WHT would apply to interest payments.
Online HMRC list is dated 1 April 2019. There is a new Double Tax agreement applicable for CT from 1/4/2019 but IOM is not on HMRC's list.
b) Where the interest is accrued and added to loan capital, does late interest provisions apply if IOM is not a qualifying territory? ie no tax deduction for interest accrued for tax comp purposes - only when it is physically paid.
IOM co wholly owned by parents and UK co wholly owned by son. No other interco transactions. I've still to look at rate of interest to see whether excessive - any thoughts on what is 'normal' these days? (And if excessive then presumably WHT will apply to excessive part of payment even if IOM is a qualifying territory)