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A public business entity has enquired whether the fees it receives for issuing guarantees should be subject to withholding tax for Corporation Tax. The DGT has ruled that, as the issuance of guarantees forms part of its economic activity, these fees are not considered income subject to withholding.
This ruling clarifies that fees derived from core business activities, such as issuing guarantees, do not trigger withholding tax obligations, providing legal certainty for public business entities regarding their tax treatment.
The tax team reviews your specific situation.
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