Andrew Parkes and Bradley Phillips published in Tax Journal

Directors Andrew Parkes and Bradley Phillips provide their thoughts on proposals for UK payers of interest to overseas lenders to apply treaty relief on interest payments without prior HMRC clearance, and Foreign Breach Exemption reforms, in Tax Journal.

Andrew and Bradley’s thoughts were published in Tax Journal, 15 July 2026.

Bradley highlighted that the consultation document around treaty relief on interest payments refers to the Government needing to consider appropriate safeguards, and stressed that ideally any proposed safeguards will not result in just a different form of administrative pain.

Andrew delved into the issues around the introduction of the Foreign Breach Exemption in 2011, discussing the winners and losers as the exemption is now being made mandatory for accounting periods on or after 1 January 2027 and from 1 September 2026 for oil and gas exploration and extraction.

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