The UK's double tax treaty passport (DTTP) scheme was introduced in 2010 as a mechanism to simplify the process by which non-UK lenders could receive interest payments from UK borrowers without deduction for withholding tax under the terms of applicable double tax treaties.

However, until April 2017, the DTTP scheme only applied to loans where both the borrower and lender were corporates. From April 2017, HMRC has extended the DTTP scheme to all types of borrower and certain lenders (including partnerships and pension funds), provided that the requisite conditions are met.