Double Taxation Treaty Passport Scheme

HM Revenue & Customs (HMRC) has launched a Double Taxation Treaty Passport (DTTP) Scheme for overseas corporate lenders. The Scheme applies only to loans taken out on or after 1 September 2010.

An overview of the scheme

Here is a basic outline of how the scheme works. Please note: HMRC's Double Taxation Treaty Passport Scheme is for overseas corporate lenders only. Individuals are not eligible.

  • An overseas corporate lender in a country with which the UK has a double taxation treaty that includes an interest or income from a debt-claims Article, may apply for a 'Treaty Passport' from HMRC.
  • If a Treaty Passport is granted by HMRC, the passport holder is entered onto the publicly available register with a unique DTTP number. Follow the link below to view this register on the HMRC website.
  • Prospective UK resident corporate borrowers should check HMRC's online register (Register of Double Taxation Passport holders) to verify the lender's Treaty Passport holder status.
  • If the UK borrower enters into a loan agreement with a lender who is registered as a Treaty Passport holder, the lender will notify them of their passport holder status and reference number.
  • The UK borrower should then notify HMRC within 30 working days of the 'passported' loan. The notification should be made using form DTTP2. Form DTTP2 can be completed and sent to HMRC online or it can be downloaded, filled in and returned to HMRC by post. (See the section below)
  • HMRC will use the DTTP2 notification details to issue a 'Direction' to the UK borrower to pay the interest with Income Tax deducted at the rate set out in the relevant Double Taxation Treaty.
  • For non-Treaty Passport situations, the normal 'certified double taxation claim' remains the default method for applying for Double Taxation Treaty Relief.

Find more detailed information about the DTTP Scheme (PDF 37K)

Read answers to questions about the DTTP Scheme (PDF 59K)

Go to HMRC's Register of Double Taxation Passport Holders (PDF 112K)

Overseas lenders - registering for a Double Taxation Treaty Passport

Any overseas corporate entity - or concern treated by its country of residence as corporation for tax purposes - may apply for recognition as a Double Taxation Treaty Passport Holder.

To register for a Treaty Passport, please read the terms and conditions and then complete form DTTP1. There are instructions on the form to help you.

Read terms and conditions for the DTTP Scheme (PDF 39K)

Download form DTTP1 (PDF 674K)

How UK borrowers tell HMRC about a passported loan

UK borrowers can use online form DTTP2 to tell HMRC about a 'passported' loan. Using the online form will help ensure that HMRC has all the information they need to consider making a Direction. Remember that the Scheme applies only to loans taken out on or after 1 September 2010.

Go to online form DTTP2

If you choose not to use the online form, you can download form DTTP2. The form contains instructions on how to fill it in. Please send your completed form to HMRC at the following address:

HM Revenue & Customs
Large Business Service
Double Taxation Treaty Team
Barkley House
Castle Meadow Road
Nottingham
NG2 1BA

Download form DTTP2 (PDF 90K)