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Stuart Pibworth

Counsel
Stuart Pibworth is counsel in the European Tax practice at Weil, Gotshal & Manges. He advises clients on a broad range of complex UK and cross-border international tax matters spanning a variety of sectors, with particular focus on: restructurings and insolvencies; liability management exercises; corporate and private equity transactions, reorganisations and joint ventures; and complex finance arrangements. Email: stuart.pibworth@weil.com

Articles by author

No guarantees: UK corporation and withholding tax complexities of guarantees

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.

9 JUN 2025