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HMRC internal manual

International Manual

Double Taxation applications and claims: applicants/claimants: pension funds: Who can claim on behalf of a pension fund

Claims are usually made by the trustees of the pension fund.

Because of the nature of a pension fund, it is difficult to hold that any party can be regarded as meeting the classical definition of beneficial ownership. See INTM332000 in regard to the fund’s assets and income.

But for the practical purposes of processing claims to relief from UK tax, we accept claims made by the trustees of the pension fund in their capacity as representatives of the fund’s members.

So where beneficial ownership is a condition for relief under a double taxation agreement, we regard the trustees of a single discrete pension fund as being capable of meeting this requirement.