RE:UK response to simplifying treaty relief from withholding tax on interest

We submitted our response to HMRC’s consultation on simplifying treaty relief for withholding tax on interest. As a capital-intensive sector, the tax treatment of interest costs are very important. We support a simplification in the current approach and, in particular, stress the need to reduce the compliance burden for taxpayers, whilst also balancing the need for providing early certainty on tax treatment for both parties. Furthermore, the system should have a proportionate approach to sanctions, especially where there is no loss of tax involved.