Tax on corporate lending and bond issues Country Q&A tool

Search the Country Q&A in the Tax on Transactions Global Guide by question and jurisdiction.

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Step 3: Scroll down to view answers and check law stated dates for each jurisdiction.

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Tax authorities

1. What are the main authorities responsible for enforcing taxes on finance transactions in your jurisdiction?

Pre-completion tax clearances

2. Is it possible or necessary to apply for tax clearances from the tax authorities before completing a finance transaction?

Disclosure of finance transactions

3. Is it necessary to disclose the existence of any finance transactions to the tax authorities?

Taxes on corporate lending/borrowing

Taxes potentially chargeable on amounts receivable

4. What are the main corporate taxes potentially chargeable on interest and other amounts receivable under a loan?

Tax reliefs available for borrowing costs

5. What corporate tax reliefs are available for borrowing costs (including interest and other amounts payable under a loan)?

Tax payable on the transfer of debt

6. What corporate, transfer, stamp or other taxes are payable on the transfer of a debt under a loan?

Withholding tax

7. Is there withholding tax on interest or any other payments under a loan?


8. Do any particular tax issues arise on the provision of a guarantee?

Bond issues

9. For corporate taxation purposes, are bonds treated any differently from standard corporate loans?

Taxes payable on the issue and/or transfer of a bond

10. What stamp, transfer or similar taxes are payable on the issue and/or transfer of a bond?


11. Are any exemptions available?

Plant and machinery leasing

Claiming capital allowances/tax depreciation

12. What are the basic rules for enabling the lessor or lessee of plant and machinery to claim capital allowances/tax depreciation?

Rate of capital allowances/tax depreciation

13. What is the rate of capital allowances/tax depreciation; does it depend on the type of assets?

Lessees not carrying on business in the jurisdiction

14. Are there special rules for leasing to lessees that do not carry on business in your jurisdiction?

Taxation of rentals

15. How are rentals taxed?

Rulings and clearances

16. Is a ruling or clearance necessary or common?

Restructuring debt

Unpaid or deferred interest or capital

17. What is the tax treatment of the borrower and the lender if interest or capital is unpaid or deferred?

Debt write-off/release and debt for equity swap

18. What is the tax treatment of the borrower and lender if a loan is:
  • Written off or released (wholly or partly)?

  • Replaced by shares in the borrower (debt for equity swap)?



19. Briefly explain the key features of the tax regime applicable to securitisations, including details of any specific tax rules that apply or issues that arise in relation to securitisations.

Foreign Account Tax Compliance Act (FATCA)

20. Has your jurisdiction entered into an intergovernmental agreement (IGA) to implement FATCA, or do you intend to enter into an IGA to implement FATCA?
21. Have there been any particular difficulties in light of your jurisdiction's domestic legislation with implementing the FATCA requirements?
22. Are there any provisions of your jurisdiction's IGA and/or domestic implementing legislation, if any, that are more onerous than the US FATCA requirements?

Bank levies

23. Are there any bank levies or similar taxes imposed specifically on financial institutions?
24. On what are any such levies or taxes charged?
25. At what rate(s) are the levies or taxes charged?
26. Are there any thresholds or exemptions?


27. Please summarise any proposals for reform that will impact on the taxation of finance transactions described above.
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