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HMRC internal manual

International Manual

HM Revenue & Customs
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DT applications and claims - Provisional Treaty Relief Scheme for Interest

One to One loans

Only loans that are between unrelated (no cross-shareholdings) parties are eligible forinclusion in the Provisional Treaty Relief Scheme. If a UK company borrows money from itsoverseas parent company that loan is not eligible for inclusion in the scheme.

If there is any “special relationship” between the parties the loan cannot beincluded in the Scheme.