Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Borrower definition

What does Borrower mean? In practice, the borrower is the person or entity that receives credit under a loan or facility agreement and undertakes to repay it. The term is descriptive rather than fixed by statute; finance documents define “Borrower” for that contract. Usage is broadly consistent across England and Wales, Scotland, Northern Ireland and Ireland, although consumer credit legislation often uses “debtor” or “consumer” instead. Key features: - The party to whom a lender, asset-based lender or receivables financier makes a facility available (for example, a term loan, revolving credit facility, borrowing‑base/ABL facility or invoice finance). - May be a single borrower or co‑borrowers within a...

UK corporate borrowing from overseas lenders: withholding tax (DTT/DTTP, QPP), deductibility (CIR, hybrids, transfer pricing), stamp/SDRT, VAT, FATCA, bank levies, Pillar Two, and forthcoming FA 2026 changes

Published by a LexisNexis Tax expert

Practice notes

FORTHCOMING CHANGE relating to UK transfer pricing legislation:

Finance Act 2026 (FA 2026) introduces a suite of revisions to the UK’s transfer pricing regime. Effective for accounting periods commencing on or after 1 January 2026, once enacted, the rules will, among other reforms, disapply UK-to-UK transfer pricing (with limited carve-outs to block tax arbitrage), revise the participation condition, and implement a range of updates to the financial transactions provisions so that UK requirements are closely aligned with the OECD Transfer Pricing Guidelines. In parallel, the government also confirmed at Budget 2025 that it will move ahead with an obligation for in-scope multinationals to submit annual information on cross-border related party dealings for accounting periods beginning on or after 1 January 2027—the detailed regulations for the new ‘International Controlled Transactions Schedule’ (ICTS) are anticipated in spring 2026 in due course. For further detail and background, see Practice Notes: Transfer pricing—the UK legislation and Tax—Finance Act 2026 tracker—progress through Parliament [Archived] and News Analyses: Finance Bill 2026—reform of UK law in relation to transfer pricing, permanent establishment and diverted profits tax and Budget 2025—Tax analysis—International...

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Alex Rigby

Skadden

Alex Rigby represents a broad range of clients on U.K. and international tax matters. His practice includes representing clients on high-value tax controversy matters, including enquires by the U.K. revenue authorities, transfer pricing disputes and competent authority work such as APAs and MAPs. He also advises on a range of transactional tax matters, including public and private mergers and acquisitions, joint ventures, equity and debt issuances, demergers and restructurings, generally with an international component.In recognition of his work on contentious matters, Mr. Rigby was named a Rising Star in Tax Controversy in ITR World Tax 2025 edition.Mr. Rigby contributes to a number of Skadden’s pro bono projects, and has advised various individuals on their appeals against benefit decisions by the Department for Work and Pensions....

Jisun Choi

Skadden

Jisun Choi advises a wide range of clients, including multinational corporations in various industries, private equity funds and financial institutions, on international and U.K. corporate tax matters, with a particular transactional focus on mergers and acquisitions and group restructurings, as well as associated financings.Ms. Choi’s practice involves structuring and advising on the tax aspects of:• private and public acquisitions and disposals of businesses, including management buyouts, sales of businesses in administration and auction sales• international group holding structures, including on joint ventures, the use of the U.K. as a holding company jurisdiction, and investment and asset management structures• group reorganisations and restructurings, including de-mergers of businesses and post-acquisition integration planning• capital market transactions, including initial and secondary listings of equity and debt instruments, and return of value to shareholders• banking and derivative transactions, including bank credit facilities and private placement arrangementsIn addition, Ms. Choi has...

Web page updated on 22/05/2026

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