UK Double Taxation Treaty Passport (DTTP): relief at source from withholding tax on interest—lender eligibility and passporting, borrower DTTP2 notifications, HMRC directions, duration, renewal and ongoing obligations
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Practice notes
The double taxation treaty passport (DTTP) scheme
The DTTP offers an alternative to the standard certified route for securing full or partial relief under a relevant double tax treaty (DTT) from UK taxation on UK source yearly interest paid to an overseas lender that is entitled to such relief. If the application is approved, the borrower paying UK source yearly interest is freed—entirely or to the extent provided by the applicable DTT between the UK and the lender’s jurisdiction of residence—from the requirement to withhold, and to account to HMRC for, UK income tax that would otherwise arise on that interest paid to the non‑UK resident lender.
This Practice Note describes how to claim DTT relief via the DTTP scheme and sets out the next steps once the DTTP has been successfully applied to a loan.
For more information on:
- what qualifies as interest, yearly interest and UK source for the purposes of the duty to withhold an amount for UK income tax from a payment of UK source yearly interest, see Practice Note: UK withholding tax on yearly interest
- the mechanisms in place, and the obligations on a borrower in
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Web page updated on 22/05/2026
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Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...
I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...
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