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.
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.
