Financing Briefing - HMRC's Double Taxation Treaty Passport Scheme - what corporate borrowers need to know

  • June 2010
  • Newsletter/briefing

HMRC recently announced the launch of a long-awaited Double Taxation Treaty Passport ("DTTP") scheme for overseas corporate lenders who rely on a double tax treaty for relief from withholding tax on interest payments by or from UK borrowers.

When the DTTP scheme becomes operative on 1st September 2010, the process of obtaining Treaty clearance should become considerably simpler in relation to lenders who have applied for and obtained a DTTP. This briefing outlines the background to HMRC’s proposal, its main features and its implications for corporate borrowers and loan documentation.

 
 

Contacts

 

Andrew Balfour (partner), Graham Airs (partner), William Watson (partner), Kathrine Meloni (professional support lawyer)

 
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