7 April 2017
The Double Taxation Treaty Passport (DTTP) Scheme is critical for funds and other non-UK lenders active in the UK loan market.
However, the DTTP Scheme has historically only applied where borrower and lender are both corporate entities. Following a recent consultation, these limitations are being mostly removed. This briefing considers the practical implications.
HMRC Double Taxation Treaty Passport Scheme: what the 2017 changes mean for borrowers, lenders and the UK loan market