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HMRC internal manual

International Manual

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HM Revenue & Customs
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DT Agreements: France - Income from a UK source paid to a resident of France

Claims by French pension funds

When you receive a DT dividend claim from a French pension fund (caisse de retraite)you should be able to recognise it from the certification given by the French Revenue.Despite the subject to tax condition of the dividend article, Article 9(3) (see INTM350600) provides that a pension fund which has been approvedfor tax purposes by France will be deemed to be subject to tax in France on UK dividendsbeneficially owned by it.