Our articles are written by experts in their field and include individual barristers, solicitors, academics, judges, and leading firms in relevant areas of practice. JIBFL offers authoritative insights into global banking and financial law, providing essential updates for legal practitioners and policymakers. Covering key topics like lending, security interests, derivatives, debt capital markets, banking and finance related disputes, crypto, FinTech and financial regulation, JIBFL serves as a trusted resource for navigating complex legal challenges and staying informed in the financial sector. If you would like to contribute, please email .

No guarantees: UK corporation and withholding tax complexities of guarantees

9 June 2025 / Author(s): Jenny Doak , Stuart Pibworth
Issue: June 2025 / Categories: Feature

The UK corporation and withholding tax treatment of guarantee arrangements and related payments is complex. Once the legal nature of the various guarantee relationships is understood, the UK tax analysis can be applied. However, even then difficulties can emerge in determining the UK tax corporation and withholding effect of guarantee arrangements given the lack of case law, guidance and legislative provisions specific to guarantees.

If you are already a User, sign in
Or you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Alternatively you can subscribe here to read unlimited content.