Market leading insight for tax experts
View online issue

UK/Netherlands agreement on dividends

printer Mail

The UK and the Netherlands signed a competent authority agreement in December, setting out the conditions and documentary evidence necessary for insurance companies resident in the Netherlands with pooled pensions business to qualify for the treaty exemption from Netherlands tax on dividends, where the beneficial owner of the dividends is a UK pension scheme. The agreement entered into force on 22 December 2016. Documentation to be provided in support of a claim includes:

  • confirmation that the insurance company is claiming only in respect of ‘pension business’ as defined in FA 2012 s 58;
  • a schedule of all of the pension schemes to which the claim relates and confirmation that these are registered UK schemes;
  • where pension business is reinsured from other insurance companies, a schedule of the names and addresses of those insurance companies;
  • confirmation that none of the above companies will make a claim for similar treaty benefits;
  • a letter of confirmation from HMRC to accompany the first claim and annually thereafter.


Issue: 1342
Categories: News