HMRC consultation on treaty clearance procedure - ACT Response

BY EMAIL

Business International
Financial Transfer Pricing
100 Parliament Street
London SW1A 2BQ

For the attention of Andy Martyn

Dear Sirs

UK treaty clearance process - relief from withholding tax on corporate interest

The LMA and the ACT jointly wish to respond to your letter of 26 February 2009 inviting comments on the arrangements for non-resident lenders claiming treaty relief from interest withholding.

The LMA and the ACT are grateful that this area is being reviewed. We believe you are aware of the proposal submitted by the ACT and the LMA to the Financial Services Secretary, Lord Myners, and copied to Win Bischoff and Dave Hartnett. We attach a copy for your ease of reference.

We should start by saying that our proposal, and this letter, relate to syndicated loans granted on standard commercial terms by lenders acting at arm's length.

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