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HMRC internal manual

International Manual

DT applications and claims - Provisional Treaty Relief Scheme for Interest

Syndicated Loans

These loans are generally for very large amounts of money that one bank is either not able or not willing to lend on its own, so that a group of lenders are brought together into a syndicate in order to provide the finance. For such a syndicate to be eligible for entry into the Provisional Treaty Relief Scheme (PTRS), the following elements must be present:

  • A group of banks are brought together into a syndicate organised and run by Syndicate Manager
  • The banks agree to jointly lend the money
  • Only corporate UK borrowers (companies) are involved
  • The Syndicate Manager makes an application to CAR Residency on form PTR-SM1
  • CAR Residency issues a letter accepting the loan into the scheme - form PTR-SM2
  • CAR Residency sends form 4450/1FD and a copy of the loan agreement to the tax office for the UK borrower asking for a report
  • If no objections are made by the Inspector of Taxes who is responsible for the borrower, CAR Residency issues a Direction under the terms of SI1970/488.