Double taxation treaty passport scheme for tax transparent debt funds

Question

My client is a non-UK tax transparent debt fund (in the form of a partnership all of whose partners are tax resident in the same non-UK country) which is able to claim full exemption from UK withholding tax on interest under the applicable double tax treaty with the UK. It would like to lend to UK borrowers and access the revised double taxation treaty passport (DTTP) scheme for the purposes of benefiting from the double tax treaty. Can it do so and what are the key practical issues it needs to consider?

Answer

Tax transparent debt funds which are entitled under the applicable double tax treaty with the UK to a full exemption from withholding tax on interest arising in the UK (because each of their members are tax resident in the same jurisdiction and are treaty...