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One-to-one aspect discontinued
Following changes in 2007 to HMRC's double tax (DT) treaty relief processes and the introduction of the DT treaty passport scheme, effective from today, the one-to-one loan aspect of the provisional treaty relief scheme (PTRS) is no longer needed.
It has therefore been discontinued.
The part of the PTRS dealing with syndicated loans has been retained under the name syndicated loan scheme (SLS). This enables DT treaty relief to be given from withholding tax, which is deductible on UK source interest paid to the lending members of a syndicate resident in countries that have treaties with the UK that provide for such relief.
The SLS applies only where the borrower and the lenders are unconnected and the transaction is on arm's length terms.
