US Double Taxation Convention: definition of “pension scheme”

Following the US Double Taxation Convention of 2001 HMRC entered into a competent authority agreement with the IRS to give an expanded definition of “pension scheme” for treaty benefits under Article 10(3)(b) (Dividends), notably to include unit linked pension policies.  The text of this agreement can be hard to find.  It is at http://www.irs.gov/pub/irs-utl/competent_authority.pdf on the IRS website and at http://www.hmrc.gov.uk/manuals/dtmanual/dt19939zd.htm on the HMRC website.