IFM02700 - Authorised investment funds (AIFs): Double taxation treaties
AIFs are within the charge to UK taxation and accordingly are entitled to benefit from treaty rate withholding taxes being deducted from overseas dividends.
Any overseas withholding tax deducted in excess of the treaty rate will typically be reclaimed from the appropriate overseas tax authority.
Requests for Certificates of Residence for AIFs should be made to HMRC’s Collective Investment Schemes Centre.