HMRC has revised the Double Taxation Treaty Passport (DTTP) Scheme with effect April 2013 to improve the customer experience.

The DTTP provides a swifter and more efficient method of providing double taxation treaty relief on UK loan interest payments made by a UK corporate borrower to overseas corporate lenders which have been recognised by HMRC as residents of countries with double taxation arrangements with the UK. As such, they will be treated as 'treaty passport holders', subject to the terms and conditions.

The scheme is for overseas corporate lenders only and applies only to loans taken out on or after 1 September 2010.

There are two significant changes following the revisions, the first being the removal of the requirement for the UK borrower company to send a completed form DTTP2 notification to HMRC within 30 working days of the start of the borrower's loan relationship with the lender. Instead, the borrower should send the form to HMRC at least 30 working days before the first interest payment is due on the loan.

The second important change is that HMRC will now, in certain circumstances, consider issuing a treaty passport to a US disregarded LLC or US S-Corporation.

More details are available from HMRC