The proposal in a consultative document published in March this year to restrict the long-standing exemption from UK withholding tax on interest paid on a quoted eurobond where the eurobond was held by a foreign affiliate of the bond issuer and listed on an exchange where there was no substantial or regular trading on the eurobond caused alarm for many multinational groups. Groups have for many years used quoted eurobonds for their financing arrangements to enable the flow of funds between group members in a way that kept compliance burdens and obstacles such as the need to apply for treaty relief from various tax authorities to a minimum. Ending the exemption would have meant that any structures which relied on it would have to be identified then reviewed...