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 “special relationship” between the parties the loan cannot beincluded in the Scheme.