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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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UK residents with foreign income or gains: claims for double taxation relief against UK tax: unit/investment trusts

The Association of Investment Trust Companies and the Association of Unit Trusts and Investment Funds have, following discussions with HMRC, recommended their members to present their double taxation relief claims so as to show separately for each country the income from dividends and the income from interest, with the total foreign tax thereon in each case. This layout should simplify the examination of such claims, making it easier to detect the inclusion of non-qualifying taxes (see for example the Double Taxation Relief Manual at DT12753 (HMRC website) (external users can find the guidance at http://www.hmrc.gov.uk/manuals/dtmanual/DT12753.htm) regarding tax deducted from Malaysian dividends) or of withholding taxes which exceed the appropriate rates in the relevant agreements. Where necessary, Inspectors should ask unit trusts and investment trusts to present double taxation relief claims on these lines.

Subject to the following conditions, no objection need normally be taken to a request by a trust that, in consideration of their adopting the recommended layout, itemised schedules and vouchers may be dispensed with. The conditions are

  1. that particulars are invariably given of any items which distort the normal ratio of tax to income for the country and type of income concerned, and
  2. that the trust agrees to furnish supporting schedules and vouchers on request.