HMRC have published a response to their consultation ‘Double Taxation Treaty Passport scheme review’.

The Double Taxation Treaty Passport (DTTP) scheme is an administrative simplification for cross border loans between companies.  It allows borrowers to apply lower treaty rates of withholding tax to interest paid to registered lenders without having to apply to HMRC for approval.

The purpose of the original consultation was to explore whether HMRC should renew and extend the existing DTTP scheme.

In their response document HMRC state that:

  • The DTTP scheme is extended to all UK borrowers from 6 April 2017, including partnerships, individuals and charities.
  • From 6 April 2017 the following can be admitted to the scheme as lenders:
    • Transparent entities (including partnerships) provided all the beneficial owners of their income are resident in the same territory and entitled to the same treaty benefits.
    • Sovereign wealth funds
    • Pension funds.
  • Digital changes are being considered, but won’t happen in the near future.
  • There are no changes to filing and other requirements under the DTTP scheme.
  • There are no plans to increase the duration of passports beyond 5 years, or introduce additional sanctions.


Our subscriber guide:

Withholding tax

Consultation documents:

Double Taxation Treaty Passport scheme review

HMRC published updated DTTP guidance to reflect these changes on 6 April 2017.

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