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

HM Revenue and Customs has been reconsidering the treaty clearance processes whereby non resident lenders can be paid interest by UK companies without withholding tax deducted. In the view of the ACT the current procedures are time consuming and administratively burdensome. Accordingly the ACT, working together with the Loan Market Association, has made a joint submission to HMRC proposing a new form of clearance based on a ‘passporting’ scheme.

• ACT summary of the issues and the ‘passporting’ proposal
  extract from The Treasurer
• Joint ACT / LMA submission to HMRC re treaty relief
• HMRC launches Double Tax Treaty passport scheme – June 2010