Tax updates: August 2013

There has been a flurry of activity from the Courts and tribunals. Key decisions are highlighted, together with other recent developments

Double Taxation Treaty Passport scheme revised

HMRC has announced changes to its Double Taxation Treaty Passport Scheme for overseas corporate lenders that are designed to enhance the scheme's effectiveness, based on operational lessons learnt since the scheme's inception.

The changes include a relaxation to the filing requirements of the UK borrowing company, and confirmation that HMRC may now consider issuing treaty passports to certain US disregarded Limited Liability Companies or 'US S-Corporations'.

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