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Commentary

E1.404 Interest—charge to tax

Personal and employment tax

E1.404 Interest—charge to tax

Income tax is charged on interest1 as savings and investment income of the person entitled to or receiving the interest2. For cases upholding HMRC's interpretation of 'the person entitled to the interest' within section 371, see Bingham v HMRC3 and Coxon v HMRC4.

Tax is charged on the full amount of the interest arising in the tax year, subject to special rules for foreign income (see Division E1.6)5 and accrued interest on dormant assets (see E1.404A).

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