DT14001 - Double Taxation Relief Manual: Guidance by country: Netherlands: Persons Covered
The treaty contains the usual provision that it applies to persons who are residents of one or both of the Contracting states.
In this respect, there has been an agreement between the competent authorities of the Netherlands and the United Kingdom as to how the treaty is to apply to investors in closed funds for mutual account, 鈥渇onds voor gemene rekening鈥� (closed FGR).
A closed FGR is fiscally transparent and income and gains derived by the fund are allocated to the investors in proportion to their participation in the fund.
The competent authority agreement outlines how a closed FGR fund manager or investor can seek treaty benefits.
If using the HMRC Intranet, the competent authority agreement can be viewed through the 鈥淣ew treaties/protocols in force鈥� link on the sidebar. On the HMRC web-site, searching for 鈥淭reaties in force Netherlands鈥� will provide a link to the agreement.