UK and the Netherlands agree on protocol regarding CIFs

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The Competent Authority Agreement is a mutual agreement regarding the application of the Convention between the government of the UK and the Netherlands for the avoidance of double taxation and the prevention of tax evasion.
The Competent Authority Agreement is a mutual agreement regarding the application of the Convention between the government of the UK and the Netherlands for the avoidance of double taxation and the prevention of tax evasion, specifically on income and capital gains related protocol signed on the 26th of September 2008 to UK pension scheme and charity investors in UK Common Investment Funds (CIFs).

A CIF is an arrangement where a number of registered pension schemes have collected their savings into a common fund for investment purposes. The CIF must be no more than an investment agency for the assets of participating schemes.

Charity CIFs are set up by schemes made by the Charity Commission (the Commission) under the Charities Act 2011. They operate as investment vehicles and are deemed by law to be charities and are therefore entitled to register as charities in their own right.

The competent authorities of the Netherlands and the UK agree that a CIF is fiscally transparent in both countries. As such, all income and gains resulting from the fund assets are allocated to the investors proportionally to their initial input, and if a CIF intends to make a claim for benefits on behalf of an investor, the custodian, manager or its depository should clearly communicate this to avoid duplicate claims on the same income.