HMRC have opened a consultation which will enable HMRC to review the Double Taxation Treaty Passport (DTTP) scheme to ensure that it still meets the needs of UK borrowers and foreign investors.
It also seeks views on extending the scope of the DTTP scheme to investors entitled to sovereign immunity from UK tax (“sovereign investors”), pension funds and other entities.
The consultation document can be found here and is open until 12 August 2016.
DTTP was introduced as an administrative simplification in late 2010. It is available to corporate-to-corporate lending into the UK in order to reduce the burden of accessing reduced rates of withholding tax (WHT) under the relevant tax treaties.
Whilst the consultation may be of little relevance to the majority of payrollers, it could be relevant to those who have involvement in pension funds.
