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Double taxation treaty passport scheme: expanding the scope

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HMRC has published updated terms and conditions and guidance for the double taxation treaty passport (DTTP) scheme, which expands the scope of its application. The DTTP scheme previously applied only to corporate lending. However, from 6 April 2017 borrowers who are individuals, partnerships or charities, and lenders who are partnerships, pension funds or sovereign wealth funds can also use the DTTP scheme. This is good news for borrowers and lenders operating in the UK market, as the DTTP scheme offers a swifter and simpler route for obtaining relief under UK double taxation treaties than the traditional ‘certified claim’ method.

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