On 20 November 2015, the Upper Tribunal16  held that a multi-factorial approach should be applied in answer to the question as to whether interest had a UK “source”. The decision of the First-tier Tribunal (as to which, see our blog here) was upheld. In particular, the Upper Tribunal supported HMRC’s published view that the residence of the debtor is material in determining the “source” of a payment of interest.

The decision can be found here.