The double taxation treaty passport scheme (DTTP scheme)

Published by a ��Ӱ�� Tax expert

Practice notes

The double taxation treaty passport scheme (DTTP scheme)

Published by a ��Ӱ�� Tax expert

Practice notes

The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and obtain an expedited authorisation to pay UK source interest to a non-UK lender in accordance with the reduced rate of withholding tax (which could be 0%) provided for in the relevant double tax treaty (DTT) with the UK if the lender has already obtained a passport certifying that it is resident in the relevant jurisdiction and entitled to the benefit of the relevant DTT between that jurisdiction and the UK.

The current DTTP scheme took effect for loans entered into (or transferred) on or after 6 April 2017 and the terms, conditions and guidance for the current DTTP scheme were updated in October 2023. There was also a minor update in April 2024, which only removed a reference to ‘DTTP30620 DTTP2A process—syndicated loans’ from the table of contents in order to reflect the fact that the underlying page, DTTP30620, does not exist in the document.

This Practice Note explains:

•
how the DTTP scheme provides a simpler and faster method of

Jurisdiction(s):

United Kingdom

Key definition:

Double taxation definition

What does Double taxation mean?

This refers to the payment of tax twice, both at the point of payment and at the point of receipt where the payment is received in a country that is not the country in which it was paid. Countries may voluntarily enter into double taxation agreements to prevent tax being levied twice.

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