Double Taxation Treaty Passport Scheme
How to apply for or renew a Double Taxation Treaty Passport and how to tell HMRC about passported loans, for overseas lenders and UK borrowers.
What the passport scheme is
The Double Taxation Treaty Passport Scheme (DTTPS) provides for Double Taxation Relief on UK source loan interest payments, to some overseas lenders.
Who can apply
You can apply to HMRC for a Double Taxation Treaty Passport if your company or concern (or its head office):
- is resident in a country that has a double taxation treaty with the UK — find out about tax treaties
- is an overseas lender including USA limited liability companies (LLC) or USA corporations that pass corporate income, losses, deductions and credits to their shareholders for federal tax purposes
You should only use the DTTPS for loans that meet all conditions for relief under the relevant double taxation arrangements.
How to apply
Find out how to apply for or renew a Double Taxation Treaty Passport.
The form includes guidance on how to complete it and where to send it to.
We’ll then consider your application.
If your application is accepted
When we accept your application we’ll:
- send you a letter
- give you a unique Double Taxation Treaty Passport reference number
- make your company’s details publicly available on a register to help borrowers verify a passport holder’s status
You must then:
- give any borrowers your reference number
- tell any borrowers to send HMRC form DTTP2
How to renew your passport
Your passport status will normally last for 5 calendar years.
We do not issue reminders when a treaty passport is due to expire.
You must:
- complete a renewal request within 3 months of your passport expiry date
- tell us in your renewal if there have been any material changes — you can find examples of material changes in the DTTPS terms, conditions and guidance
If your renewal is not received by the expiry date your passport holder status will be withdrawn.
When you send us a renewal, if there have been no material changes since the original passport it will be renewed for a further 5 year period.
You do not need to give us further certification of tax residence, but we may ask for this in future.
Find out how to apply for or renew a Double Taxation Treaty Passport.
If there are changes to passport holders or borrowers details
You must tell HMRC if there are any changes to your own business details or changes to the borrowers, for example, changes in country of residence or owner. If you do not, we may remove your passport holder status.
Tell HMRC about a passported loan
Borrowers must tell us of any passported loan using form DTTP2. This should be done as soon as possible once the loan arrangement is entered into, to allow us time to review the application.
Until you receive a Direction letter from us, you must withhold tax from the interest payments, unless we tell you that DTTP30610 applies. You can find out about DTTP30610 in the DTTPS terms, conditions and guidance.
HMRC reviews
We may periodically review a sample of passport holders to:
- confirm that passport holders are correctly understanding and applying their responsibilities
- find areas of improvement in the scheme
- get feedback about the scheme
If we find that you’re not operating the scheme correctly, we may:
- send you a formal warning
- suspend your passport holder status for a fixed period or remove it
Last updated 20 October 2023 + show all updates
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Guidance has been added to explain we no longer issue reminders when a treaty passport is due to expire. Also borrowers should tell us of any passported loan as soon as possible once the loan arrangement is entered into, to allow us time to review the application.
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HM Revenue and Customs will write to write to passport holders 3 months before their passport expires.
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First published.