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HMRC internal manual

International Manual

EU Directive: Interest & Royalties paid between Associated Companies - claims and applications by non- residents

Business concerns that qualify to claim exemption

The link below provides a list of companies covered by Article 3(a) of the Directive (see Annex to Directive):

Link to list of companies

A company is an “associated company” if it meets the minimum shareholding requirements of Finance Act 2004/S98(4) and S99(4) that is 25% or more of the capital or voting rights.