Download the full outcome
Detail of outcome
Key elements of the government’s response are:
the scheme will be made available to all UK borrowers that have an obligation to deduct withholding tax, including UK partnerships, individuals and charities
transparent entities (including partnerships) will be admitted to the scheme as lenders where all of the constituent beneficial owners of the income are entitled to the same treaty benefits under the same treaty
sovereign wealth funds and pension funds who are utilising withholding tax treaty rates will be admitted into the scheme as lenders
As announced at Spring Budget 2017, HMRC has published the scheme’s Terms and Conditions and Guidance, which will commence for loans entered into on or after 6 April 2017.
This consultation 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.