Great thanks

Well its pretty hard going, but...…

From what I can tell under the new treaty arrangements which has come in force from 01/01/2020.

The withholding tax on payments to the UK is :

5% on dividends to UK resident companies (Otherwise 15%)

Now 0% in interest payments (apart from a few exceptions)

Also 0% on royalties.

What I'm really after is someone to confirm this for me and to point out anything with regard to Withholding taxes in Israel that I'm missing.

Thanks

Thinking about this further….

I guess the DTT will specify the ‘tie-breaker’ rules for duel residents, which is obviously a big benefit.

However, for an individual who is just UK resident?

Honestly I'm not.

My other posts, on separate threads, referred to a branch.

This is a separate entity that is not a branch.

I didn't call you boring, I said just saying 'go to an accountant' is boring, its a subtle but important difference.

Most people on this site are not looking for a fight. But just look over some random posts, its obvious there are some people being deliberately objectionable for the sake of some mild titillation.

More than happy to thank you for advice.

Agreed. Please see another response above I've just made. Hence why I want to roll it forward to use as a tax reducer in a future profitable year, rather than w/o as an expense (thus only getting a 19% deduction) when the carried fwd losses are utilised.

It is a subsidiary.

There's definitely a DTT in place.

Yes - advice was taken on level transfer pricing, and agreed with their authority.

It seems to me the WHT is 100% deductible against corporation tax as a tax reducer in the year it was withheld.

I think the main issue is - in a loss making year what happens to the WHT suffered? The whole amount has been deducted and paid over to the authority in the foreign country. But if it is written off as an expense here (rather than carried fwd on the balance sheet) we will only get a 19% deduction from CT when the loss is utilised, compared to 100% deduction if we roll it all fwd and use it as a tax reducer.

I meant fully deductible as a tax reducer, not as an expense.

Well trust me this is the exception to your rule.

I wasn't rude. Not even close. There are a lot of people on this site always looking for a fight - I'm not one of them.

But we have paid 100% of the withholding tax in the foreign country to their revenue. ie the withholding tax is on services provided to the foreign subsidiary.

From what I've read this is fully deductible against UK corporation tax in the year it occurs.

If we write if off as an expense in a loss making year, it seems unfair that we only get 19% of the value in future, where if we'd made a profit we'd get 100% relief?

Thanks