Non-residents: UK income: Returns and reports: Enquiries by FICO - general concerns
Both royalty and interest payments provide a route for money to flow out of the United Kingdom while the United Kingdom payer receives a deduction for the payments in computing his profits. We need to be vigilant when granting relief from United Kingdom tax under agreements in order to try to ensure
- that residents of those countries with which we do not have an agreement do not indirectly benefit from such relief
- that all the conditions specified in the agreement are satisfied (DT1913)
- that transfer pricing implications are considered (DT1918).Any concerns which the District has should be brought to FICO’s attention.