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HMRC internal manual

Savings and Investment Manual

Collective investment schemes: unauthorised unit trusts: taxation of the investor: foreign double tax relief

Cases involving double tax relief

Where there is a ‘foreign element’ included in a deemed payment to a unit holder, ITA07/S848 does not apply to the foreign element of the deemed deduction treated as made from any deemed payments (ITA07/S943B).

Any unit holders affected by this rule should receive an ‘annual statement’ informing them of -

  1. the date on which the deemed payment was treated as made,
  2. the gross amount of the deemed payment,
  3. the foreign element (if any) of the deemed income represented by the deemed payment,
  4. the deemed deduction made from the deemed payment, and
  5. the foreign element (if any) of that deemed deduction.