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Norfolk and Montagu on the Taxation of Interest and Debt Finance provides an authoritative, pragmatic and accessible guide to the taxation treatment of interest and debt finance for both individuals and companies.

Reissued four times a year to ensure that the content is up to date, the commentary offers unprecedented broad and deep integrated coverage of tax law (and relevant aspects of accounting practice and company law).

The text has been expanded, in recent years, to offer thematic commentary, of relevance also in many scenarios outside a financing context:

• on the approach taken by the courts to 'deeming' provisions,
• 'purpose' tests in the context of anti-avoidance rules,
• the meaning of 'payment', ‘beneficial ownership’ (including in non-UK jurisdictions) and ‘trade’,

This is a unique and invaluable resource for solicitors, barristers, accountants and all tax practitioners whether working 'in house' or in private practice.

The evolution of tax law is traced, since Pitt introduced a duty on income in 1799, to explain why the law has developed as it has (e.g. in relation to the capital/revenue distinction).

Recognising that repealed provisions can be relevant for many years, commentary relating to repealed provisions is retained in the Appendices so that it continues to be easily accessible (while clearly separated from current law).

When should you consult this resource?

The expert advice within this text is invaluable in a wide range of day-to-day scenarios including:

• determining whether interest has a UK source or whether a compensation payment could be subject to withholding tax;
• advising a private client from an income tax, CGT or IHT perspective in relation to a borrowing or a debt investment;
• determining whether a financing arrangement is disclosable under DOTAS or MDR, or in response to an information notice;
• identifying reporting obligations under the CRS and FATCA;
• planning how to raise funds for a particular project, or business (including securitisation and having regard to the UK’s Pillar 2 QDMTT and international top-up tax);
• restructuring the borrowings of a company or a group of companies.