The Double Taxation Treaty Passport Scheme provides for Double Taxation Relief on UK loan interest payments made by a UK corporate borrower to overseas corporate lenders.
Those who can apply to join the scheme are organisations (or its head office):
is resident in a country that has a double taxation treaty with the UK is an overseas corporate lender which took out a loan taken on or after 1 September 2010HMRC also considers issuing passports to:
US limited liability companies US corporations that elect to pass corporate income, losses, deductions and credits to their shareholders for federal tax purposesIf a company is registered for the Double Taxation Treaty Passport Scheme, its details will be made publicly available on this register - to help borrowers verify a passport holder’s status.
HMRC are committed to add new lenders to this list at regular intervals.
The register has been updated.
