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HMRC internal manual

International Manual

DT claims and applications: Collective Investment Vehicles

Claims by Collective Investment Vehicles – funds or trusts

Generally you cannot give relief on claims submitted in the name of collectiveinvestment vehicles that are organised as funds or trusts, or in the name of theirmanagers, trustees or custodians, where the relieving provision includes beneficialownership as a condition. This is because they are not the beneficial owners of the incomeor of the investments held in their name.

Where the condition for relief is subjection to tax rather than beneficial ownership youwill need to be sure that the collective investment vehicle satisfies this condition. Itis possible that the investor or investors in the fund rather than the fund itself will besubject to tax on the income.

Where the collective investment vehicle is not able to claim because they are not thebeneficial owners of or not subject to tax on the income, unit holders themselves may beentitled to claim relief based on their proportionate share of the collective investmentvehicle’s income on the ‘looking through’ basis.

There are some specific circumstances in which claims made by managers or trustees of anunincorporated collective investment vehicle may be accepted:

  • Irish Unit Trusts
  • Japanese Investment Funds
  • Swiss Investment Funds
  • US Mutual Funds

You may also receive a claim from a collective investment vehicle that is a company inits own right, see INTM340530.