1. Introduction
2. Interest
a. What is interest
b. When does WHT have to be stopped
c. Exemptions and reduced rates
i. Double taxation agreements
ii. Interest and Royalty Directive
d. Admin
i. Paying WHT
ii. Claims
1. For reduced rate
2. For repayment
3. For double taxation relief
iii. Treaty passport Scheme
3. Annual payments including royalties
a. What is
i. An annual payment
ii. A royalty
b. When does WHT have to be stopped
c. Exemptions and reduced rates
i. Double taxation agreements
ii. Interest and Royalty Directive
d. Admin
i. Paying WHT
ii. Claims
i.For reduced rate
ii.For repayment
iii.For double taxation relief
4. Dividends
a. Background
b. UK dividends
c. Non-UK dividends
d. Exemptions and reduced rates
i. Double taxation agreements
ii. Parent subsidiary directive
iii. Distribution exemption
iv. Underlying tax
e. Claims
5. Offshore receipts in respect of intangible property
a. History
b. The regime
c. Exemptions
d. Anti-avoidance
e. Admin
i. Payment
ii. Recovery from related persons