INTM505050 - Payment of interest overseas: deducting income tax

Exceptions to obligation to deduct: Eurobonds

Payments of interest on a 'quoted Eurobond' are excluded from the general requirement to deduct income tax.

The term 'Eurobond' reflects the development of the market for raising cross border finance, in that the first such debt securities were issued in London but denominated in US dollars. 'Eurobonds' are issued and/or traded internationally. The tax definition of 'quoted Eurobond' is different to the commercial understanding of the term 'Eurobond' (see CFM3202c for further information).

With effect from 1 April 2001, a 'quoted Eurobond' is defined in ICTA88/S349(4) as any security that

  • is issued by a company
  • is listed on a recognised stock exchange and
  • carries a right to interest.

Revenue Press Releases PR76/01 and PR120/01 give additional background on the interpretation of the expression 'listed on a recognised stock exchange'.

The definition of a recognised stock exchange is at ICTA88/S841(1). It includes the London Stock Exchange and any such stock exchange outside the United Kingdom as is approved by an Order of the Board of Inland Revenue. The current list of recognised overseas exchanges is available on the HM Revenue & Customs website at www.hmrc.gov.uk.

Before 1 April 2001, 'quoted Eurobond' was defined in ICTA88/S124 as a bearer security, carrying the right to interest which is issued by a company, listed on a recognised stock exchange and either held in a recognised clearing system or beneficially owned by a person not resident in the United Kingdom.