Jurisdiction(s):
United Kingdom

Key definition

Double taxation definition

What does Double taxation mean? Double taxation describes the same income, profits or gains being taxed twice, typically in two jurisdictions—for example, tax withheld at source and a further tax on receipt. It can be juridical (the same taxpayer taxed on the same item by two states) or economic (the same profits taxed in different hands, such as corporation tax on company profits and income tax on dividends). The term is descriptive rather than a defined statutory expression, but relief is created by legislation and double taxation agreements (DTAs/treaties). In the UK, relief for foreign tax and the effect of DTAs are provided under the Taxation...

HMRC DTTP Scheme: expedited treaty relief from UK interest withholding tax—eligibility, procedure (DTTP1/DTTP2), lender/borrower obligations and passport duration

Published by a LexisNexis Tax expert

Practice notes

permits a borrower to apply for, and secure, an accelerated authorisation to pay UK-source interest to a non-UK lender at the reduced Withholding Tax rate (which could be 0%) set under the relevant Double tax treaty (DTT) with the UK, where the lender has already obtained a passport confirming it is resident in the appropriate jurisdiction and entitled to the benefit of the applicable DTT between that jurisdiction and the UK. This expedited route operates only where the passport has been granted to that lender concerned.

The current DTTP scheme applies to loans entered into (or transferred) on or after 6 April 2017, and the terms, conditions and guidance for the present DTTP scheme were updated in October 2023. There was also a minor update in April 2024, which solely removed a reference to ‘DTTP30620 DTTP2A process—syndicated loans’ from the table of contents to reflect that the underlying page, DTTP30620, does not exist in the document.

This Practice Note explains:

how the DTTP scheme provides a simpler and faster method of obtaining treaty relief when compared with the normal certified claim method
the types of lenders that are eligible to hold a DTTP passport under the scheme
the duration of...

To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial.

Web page updated on 21/05/2026

Popular documents

Using the Judicial College Guidelines to assess general damages in personal injury claims

When evaluating a general damages claim, the practitioner ought initially to refer to the Judicial College Guidelines (JCG)...

Tomlin orders in England and Wales: CPR guidance on drafting, confidentiality, approval, variation, enforcement, limitation, CCA issues, court-specific requirements, sample wording and precedents

This Practice Note This Practice Note reviews mechanisms used in settling litigation. A Tomlin order consists of a consent order paired with a schedule. It operates to stay proceedings on terms that have been agreed. The provisions contained in the schedule may remain confidential. This Practice Note describes the scope of confidentiality attaching to the schedule and sets out how it differs from a standard consent order. Sample wording for a Tomlin order is included, alongside links to precedents, as well as guidance on court approval. It also addresses varying, setting aside and enforcing a Tomlin order, including the considerations the court will take into account when handling applications for each. Further guidance is provided on interpreting and applying the relevant provisions of the CPR; however, some courts and divisions impose very specific requirements for both drafting and approval, and for approaching the schedule and confidentiality issues. Accordingly, you must consider the particular rules and court guide provisions in the forum where your claim is proceeding when drawing up the Tomlin order...

Precedent: Deed of Surrender of Lease with Optional Premium, Settlement and Release, Landlord, Mortgagee and Guarantor Consents, Reimbursement and HM Land Registry Provisions (England and Wales)

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 ...

Precedent Statutory Declaration: Standard Wording under the Statutory Declarations Act 1835

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 ]...