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Revision for double taxation treaty passport scheme

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HMRC has announced that the  (DTTP) scheme has been revised from April 2013. The scheme operates for overseas corporate lenders in a country with which the UK has a double taxation treaty that includes an interest or income from a debt-claims article, and applies only to loans taken out on or after 1 September 2010. HMRC will now in certain circumstances consider issuing a treaty passport to a US disregarded LLC or US S-corporation.

HMRC has also removed the requirement for a UK borrower company to send a completed form DTTP2 notification to HMRC within 30 working days of the start of the borrower’s loan relationship with the lender;  the borrower should now send the form to HMRC at least 30 working days before the first interest payment is due on the loan.