IFM10700 - Double taxation treaties

An exempt unauthorised unit trust (EUUT), a non-exempt unauthorised unit trust (NEUUT) and a mixed unauthorised unit trust (MUUT) are all liable to tax in the UK and accordingly are entitled to treaty benefits, including reduced rates of withholding tax.

Any overseas withholding tax deducted in excess of the treaty rate will typically be reclaimed from the appropriate overseas tax authority, but note:

• An EUUT is very unlikely in practice to be subject to income tax and accordingly will be unable to claim credit relief for overseas withholding tax.
• A NEUUT is liable to corporation tax and therefore able to claim relief for overseas withholding tax in the same way as a UK company.
• A MUUT may in certain circumstances be able to claim credit relief for overseas withholding tax.

Requests for Certificates of Residence for all UUTs should be made to The Collective Investments Scheme Centre (CISC) whose address can be found on the Gov.uk website.