Relief from UK Withholding Tax and the New Passport Scheme

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On 1 September 2010, the new Double Taxation Treaty Passport (“DTTP”) scheme became operative. According to Her Majesty’s Revenue & Customs (“HMRC”) the new scheme will result in expedited treaty clearances and will provide a simpler and more efficient method of paying interest to overseas lenders, which has been sought after by businesses as an alternative to the present certified claim procedure for some time. This Alert outlines the main features of the new DTTP scheme and its implications for the UK borrower, overseas lender and the drafting of loan documents.

Please see full alert below for more information.

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