Cross-Border Financing after Budget 2026 – Interest Deductions, Treaty Relief and Tax Certainty

• Reviewing the financing structure: the borrower, lender, use of funds and relevant tax jurisdictions.
• Interest deductibility: transfer pricing, debt capacity and the unallowable purpose rule, including the importance of contemporaneous commercial evidence.
• Corporate Interest Restriction: its role, key computational concepts and the information required from the wider group.
• Hybrid mismatches: identifying arrangements requiring a separate review and understanding their interaction with interest deductions.
• Withholding tax: UK-source yearly interest, relevant exemptions, treaty entitlement and the procedures for obtaining relief at source.
• Tax certainty: the Budget consultation, practical documentation and a checklist for reviewing new or existing financing.

The trainer is CEO and Tax Advisor at Vectigalis Tax (Vectigalis AC Tax Limited). He advises internationally active businesses and individuals on UK and cross-border tax, with a particular focus on permanent establishment risk, corporate residence/POEM, treaty positions and documentation, and cross-border structuring (including withholding tax considerations and transfer pricing).

He lectures in International Taxation (CIOT/ADIT context) and has held senior tax leadership and advisory roles, including Head of Tax for the Diacron Group and consulting/advisory work with other International Tax firms (including Bain & Company). He has worked across multiple jurisdictions, including the UK, Italy, the US, and Costa Rica, and brings a practitioner-led, case-driven approach that is grounded in real client scenarios.

Delegates will be able to identify the principal UK tax risks in a cross-border financing arrangement, organise the review and recognise where further analysis or HMRC engagement may be required.

A practical review of the UK tax issues arising when a UK company borrows from overseas. Using a financing case study, the session will explain how to assess interest deductions, withholding obligations and treaty relief, alongside the areas being considered for simplification following Budget 2026.