HMRC has announced important changes to its Double Taxation Treaty Passport Scheme. From April 2013, the Scheme has been revised based on operational lessons learnt since the Scheme's inception and representations made by those using the service.

HMRC operates this scheme for overseas corporate lenders. It applies only to loans taken out on or after 1 September 2010.

There are two significant changes:

• The removal of the requirement for the UK borrower company to send a completed form DTTP2 notification to HMRC within 30 working days of the start of the borrower's loan relationship with the lender. Instead, the borrower should send the form to HMRC at least 30 working days before the first interest payment is due on the loan.
• HMRC will now in certain circumstances consider issuing a treaty passport to a US disregarded LLC or US S-Corporation.

Full details of these changes and on the scheme are available on the HMRC website.