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HMRC internal manual

International Manual

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

Time limit

The normal time limit provisions for making claims to the Revenue apply in most cases.See INTM330700.

Interest and Royalty payments

Normal time limits do not apply to tax that is deducted from interest and royaltypayments. This is because of Article 27(6) ‘Miscellaneous rules’ of the DTA. Where tax isdeducted from interest and royalty payments a claim can be made at any time up to sixyears after the end of the calendar year in which the tax was deducted.


Interest paid on 31 March 2004. The tax deducted from this interest payment may be claimedat any time up to 31 December 2010, that is 11 months later than the usual time limit formaking claims for 2003/04.


The special time limit at Article 27(6) also applies to tax that is deducted fromdividend payments. For all current years this has no effect for dividends that are paid byUK companies. With effect from 6 April 1973 UK dividends have not had tax deducted fromthem. Instead they have an amount attached to them (but not paid to the shareholder at thetime of the dividend) called a tax credit (ICTA88/S231). See INTM343500for more information.