INTM338550 - DT applications and claims - Provisional Treaty Relief Scheme for Interest

Syndicated Loans

»Ê¹ÚÌåÓýappse loans are generally for very large amounts of money that one bank is either not able or not willing to lend on its own, so that a group of lenders are brought together into a syndicate in order to provide the finance. For such a syndicate to be eligible for entry into the Provisional Treaty Relief Scheme (PTRS), the following elements must be present:

  • A group of banks are brought together into a syndicate organised and run by Syndicate Manager
  • »Ê¹ÚÌåÓýapp banks agree to jointly lend the money
  • Only corporate UK borrowers (companies) are involved
  • »Ê¹ÚÌåÓýapp Syndicate Manager makes an application to CAR Residency on form PTR-SM1
  • CAR Residency issues a letter accepting the loan into the scheme - form PTR-SM2
  • CAR Residency sends form 4450/1FD and a copy of the loan agreement to the tax office for the UK borrower asking for a report
  • If no objections are made by the Inspector of Taxes who is responsible for the borrower, CAR Residency issues a Direction under the terms of SI1970/488.