The competent authorities of the United Kingdom and the Netherlands have reached the following mutual agreement regarding the application of the Convention between the Government of the Kingdom of the Netherlands and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains and the related Protocol signed on 26 September 2008 to UK pension scheme and Charity investors in UK Common Investment Funds (hereinafter also referred as: ‘CIFs’).
This Agreement applies to UK CIFs whose investors are:
- Pension schemes which qualify for benefits under the above Convention;
- Charity organisations which qualify for benefits under the above Convention; and
- Other investors which qualify for benefits under a Convention for the avoidance of double taxation to which the Netherlands is a Contracting State.
A CIF can act as a pooled investment vehicle for the assets of pension schemes or charities. The CIF invests these assets on behalf of those investors.
The competent authorities of the Netherlands and the United Kingdom agree that a CIF is regarded as fiscally transparent in both countries. Since a CIF is fiscally transparent, all income and gains derived by the fund from the fund assets are allocated to the investors in the CIF in proportion to their participation in the CIF.
