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I act for a proprietary limited company (a family-owned company) resident in Australia and not resident in the UK. The company purchased the long lease of a residential flat in London in January 2005 and borrowed 100% of the cost from another family-owned Australian non-UK resident connected company which charges what it considers to be a commercial rate of interest.
For 2004-05, the loan interest paid is the largest single item of expense. No disclosure was made to HMRC's Centre for Non Residents that interest was paid to a connected non-resident company.
I act for a proprietary limited company (a family-owned company) resident in Australia and not resident in the UK. The company purchased the long lease of a residential flat in London in January 2005 and borrowed 100% of the cost from another family-owned Australian non-UK resident connected company which charges what it considers to be a commercial rate of interest.
For 2004-05 the loan interest paid is the largest single item of expense. No disclosure was made to HMRC's Centre for Non Residents that interest was paid to a connected non-resident company.
Should a proportion of the loan interest paid be disallowed by reason of the note relating to Box 2.4 of the Non-Resident Company's Tax Return Guide? Although the notes re Box 2.4 for 2004-05 and 2005-06 are roughly the same there are differences between the texts for each tax return guide. In response...
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