HMRC have announced changes to the Double Taxation Treaty Passport (DTTP) Scheme for overseas lenders. The DDTP Scheme is aimed at simplifying administration in certain cases where non-resident companies make loans to UK corporate borrowers. An overseas lender resident in a country with which the United Kingdom has a relevant double taxation treaty may apply to HMRC for a Treaty Passport. A relevant double taxation treaty is one that contains an article dealing with interest or income from debt claims. Upon obtaining a Treaty Passport, the overseas lender is entered onto a public register (administered by HMRC) and given a...