涉外律师解读国际税法：英国跨境支付相关税务规定

Group 1 - UK does not impose withholding tax on dividends paid by UK companies, except for UK Real Estate Investment Trusts (REITs) [2] - UK companies are subject to a 20% withholding tax on royalties paid to non-residents, unless exemptions or lower tax treaty rates apply [3] - UK companies must pay a 20% withholding tax on annual UK-source interest paid to non-residents, with specific conditions for exemptions [4] Group 2 - Various rules restrict the deductibility of certain interest expenses in corporate tax, following OECD BEPS recommendations [5] - No additional safe harbor rules apply beyond the corporate interest restriction rule, which only affects net interest expenses exceeding £2 million [6] - Transfer pricing rules apply to related-party guarantees, potentially affecting interest deduction eligibility [8] Group 3 - There are no specific additional restrictions on interest payments to non-residents beyond those previously mentioned [9] - A 20% withholding tax is imposed on rent paid for UK properties to non-residents, with potential for full payment under the Non-Resident Landlord Scheme [10] - UK transfer pricing rules are based on OECD guidelines and apply to transactions between related companies [11]