INTM338530 - DT applications and claims - Provisional Treaty Relief Scheme for Interest
One to One loans
Only loans that are between unrelated (no cross-shareholdings) parties are eligible forinclusion in the Provisional Treaty Relief Scheme. If a UK company borrows money from itsoverseas parent company that loan is not eligible for inclusion in the scheme.
If there is any 鈥渟pecial relationship鈥� between the parties the loan cannot beincluded in the Scheme.