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]

Group 1 - The article discusses the principle of independent transactions, emphasizing that transactions between unrelated parties should adhere to fair market prices and business norms to ensure proper tax compliance [3] - It highlights the issue of unreasonable pricing in related party transactions, where the pricing deviates significantly from market norms, leading to potential tax adjustments by tax authorities [4][7] - Various transfer pricing methods are outlined, including comparable uncontrolled price method, resale price method, cost-plus method, transactional net margin method, and profit split method, which are used to assess and adjust related party transaction pricing [7] Group 2 - The article addresses capital weakening, where companies increase debt capital while reducing equity capital to lower taxable income through deductible interest expenses [8] - It specifies the debt-to-equity ratio standards set by tax laws, indicating that exceeding these ratios may result in non-deductible interest expenses, necessitating adjustments to taxable income [8] - The concept of controlled foreign corporations is introduced, where profits from foreign entities controlled by domestic companies, which are not distributed or are minimally distributed, may need to be included in the domestic company's taxable income [9]