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HMRC internal manual

International Manual

DT applications and claims - Types of income: Interest

Permanent Interest Bearing Shares

Permanent Interest Bearing Shares are intended to form a long term contribution to theworking capital of a building society. They carry interest which is not determined by thesocieties profits and which is paid at either a fixed rate or at a floating rate.

ITA2007/S889 requires tax to be deducted from interest that is paid.

Subject to normal examination requirements relief from UK tax may be allowed under theterms of the interest article of a double taxation agreement. A direction under the termsof SI1970/488 can also be issued.