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HMRC internal manual

International Manual

Double Taxation applications and claims: applicants/claimants: pension funds: Claims under Double Taxation Agreements

Relief will be available if the claimant fund is a resident of the other country, or is treated as being resident there for the purposes of the double taxation agreement, and is entitled to relief under the provisions of the agreement.

You should give careful consideration to any conditions of the agreement which may affect relief under its relevant articles. The DT Digest gives a summary of the conditions for relief and any rates of withholding tax that may apply to pension funds. For example, some double taxation agreements provide for full relief from tax on property income dividends that are beneficially owned by a pension fund.