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HMRC internal manual

International Manual

DT applications and claims - Types of income: Interest

Privately Arranged Loans: Syndicated loans

These loans are normally arranged where some concern (normally a company) wishes tofund a large project. One lender may not be able or willing to provide all of the money.In these circumstances a group of companies (normally banks) are brought together tojointly lend the money.

It is possible for the syndicate manager to apply to include these loans in theProvisional Treaty Relief Scheme for Interest (see INTM338500).In these cases a single direction is issued under the terms of SI1970/488.

If the syndicate manager does not choose to make an application to include the loan in thePTRS then each overseas lender must make their own separate application for treatybenefits. Following normal examination principles separate directions must be issued tothe UK borrower under the terms of SI1970/488.