A deduction made at source by the payer from amounts such as interest, dividends or royalties, which the payer must account for to the tax authority rather than paying the full sum to the recipient. In practice, withholding tax is a descriptive term; the obligation to deduct and the applicable rate/exemptions are set by legislation.
Across England & Wales, Scotland and Northern Ireland, UK withholding tax on yearly interest is generally required at the basic rate under the Income Tax Act 2007 (notably section 874), subject to statutory exemptions and reliefs (for example, the quoted Eurobond exemption and relief under double tax treaties). In Ireland, interest withholding is governed principally by section 246 of the Taxes Consolidation Act 1997, with comparable exemptions and treaty relief administered by Revenue.
Withholding tax is a key issue in loan agreements, particularly where interest is paid to non‑resident lenders. Market documentation typically includes tax gross‑up, treaty co‑operation/clearance and tax credit clauses, so the lender receives the agreed gross amount unless an exemption or relief applies. Usage is broadly consistent across the UK, with a distinct but similar Irish regime. Failure to withhold when required can leave the payer liable for the tax, interest and penalties.