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HMRC internal manual

International Manual

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

Claims by Japanese “Tokkin” funds

‘Tokkin’ is an abbreviation of ‘tokutei kinsen’, and means‘designated monetary trust’.

Cash or other assets for this type of fund are deposited by the investor(s) with a trusteewho manages them on behalf of the investor(s), and in accordance with his/her/theirinstructions. The tokkin is set up and managed under the terms of a written agreementbetween the parties, drawn up under Law No 62 of 21/4/1922 of Japan.

Because the Dividends and Interest Articles of the convention provide for relief onlyto the beneficial owner (INTM332000)of the income, claims in respect of income paid to tokkin funds must bemade by the beneficial owner of the tokkin (the ‘investor(s)’ above), and cannotvalidly be made by the tokkin’s manager.

So if you see a claim or supporting voucher which makes any reference to tokkin, youshould ensure that you consider only claims made by the beneficial owner, that is, the originalinvestor, in respect of his/her/their share in the tokkin.

There is no reason why a single investor should not own all the funds ina tokkin, but you should make certain that your claim has been made by the beneficialowner and not by the trustee, or an investment manager.

The original investors/beneficial owners may be either individuals or companies.

But it should be clear in either case that no relief can be due to thetokkin itself.