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Flowchart: Appeals Against Sentence Following Summary Conviction in Scotland (Criminal Procedure (Scotland) Act 1995, Part X)

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Except where an exemption or relief is available, payments of yearly interest that have a UK source (including amounts that tax legislation treats as payments of yearly interest) must be made under deduction, with the payer required to account to HMRC for an amount in respect of UK income tax at the basic rate (20%) or, from 6 April 2027, at the savings basic rate (22%). Although often called a withholding tax, it is in fact simply a means, in practice, of collecting UK income tax. While the tax is imposed on the interest received by the non-UK beneficial owner, it is recovered from the UK-based payer of the interest. For further detail, see Practice Notes: UK withholding tax on yearly interest and Exemptions and reliefs from UK withholding tax on yearly interest. This Flowchart assists in determining whether the quoted eurobond exemption applies to a payment of interest, so that the payer need not withhold UK income tax from that payment in question. For more information on the quoted eurobond exemption, see Practice Note: Exemptions and reliefs from UK withholding tax on yearly interest—Exemption for interest on a quoted eurobond...

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Wendy Culross
Wendy Culross

Since calling to the Scottish bar in 2013 Wendy has been involved in a number of large and complex trials. She has a particular interest in Health and Safety cases following an involvement in a number of such cases while a procurator fiscal depute and deals with breaches following HSE investigations, as well as technical breaches of regulations, and cases arising from Local Authority and police investigations.Wendy represents clients at all levels of criminal case, including enjoying a busy appellate practice. She deals with criminal trials and appeals; as well as frequently representing clients in debates on preliminary issues and pleas in bar of trial. Wendy’s technical knowledge is renowned, and she is often approached for her expertise in complex and unusual issues, given her ability to analyse cases forensically and engage with innovative solutions.Wendy has been at the forefront of the...

Web page updated on 22/05/2026

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