HMRC published on 20 March 2017 the outcome of a consultation on revisiting the Double Taxation Treaty Passport Scheme (DTTPS). Key elements of the government’s response are: (i) the scheme will be made available to all UK borrowers that have an obligation to deduct withholding tax, including UK partnerships, individuals and charities; (ii) transparent entities (including partnerships) will be admitted to the scheme as lenders where all of the constituent beneficial owners of the income are entitled to the same treaty benefits under the same treaty; and (iii) sovereign wealth funds and pension funds who are utilising withholding tax treaty rates will be admitted into the scheme as lenders. As announced at Spring Budget 2017, HMRC has also published the scheme’s Terms and Conditions and Guidance, which will commence for loans entered into on or after 6 April 2017. For further information, please contact Paul Hale and Enrique Clemente.