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Clifford Chance

Clifford Chance


HMRC Double Taxation Treaty Passport Scheme: what the 2017 changes mean for borrowers, lenders and the UK loan market

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.

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