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HMRC’s double taxation treaty passport (DTTP) scheme operates for overseas corporate lenders and applies to loans taken out on or after 1 September 2010. Two main changes have been made with effect from April 2013:
HMRC’s double taxation treaty passport (DTTP) scheme operates for overseas corporate lenders and applies to loans taken out on or after 1 September 2010. Two main changes have been made with effect from April 2013:
- Removal of the requirement for the UK borrower company to send a completed form DTTP2 notification to the Revenue within 30 working days of the start of the borrower’s loan relationship with the lender. Instead, the borrower should send the form to the taxman at least 30 working days before the first interest payment is due on the loan.
- HMRC will now consider issuing a treaty passport to a US disregarded LLC or US S-Corporation.
Full details of the changes can be found in the revised DTTP overview, terms and conditions, and technical questions and answers on the tax department’s website.
