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International: Double tax relief

International: Double tax relief

HMRC has launched a Double Taxation Treaty Passport (DTTP) scheme for overseas corporate lenders. Treaty passport holders will be listed on a register available to prospective UK resident corporate borrowers. HMRC said: 'If the UK borrower enters into a loan agreement with a lender who is registered as a Treaty Passport holder the lender will notify them of their passport holder status and reference number. The UK borrower will notify HMRC within 30 days of the 'passported' loan. Form DTTP2 for this purpose will be available from the start of the scheme on 1 September 2010. HMRC will use the DTTP2 notification details to issue a direction to the borrower to pay the interest with income tax deducted at the rate set out in the relevant DT treaty.'

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