Double Taxation 0% Rate for Pension Schemes

A follow up on double taxation treaties that provide for reduced rates of withholding tax for UK pension schemes.  The double taxation agreements that provide for reduced rates that I am aware of are as follows.

Holland, Germany, Switzerland, USA, Japan and Belgium.

The reduced rates for pension schemes in these agreements should be extended to investments in respect of unit linked pension business of UK life insurance companies but there seem to be some difficulties convincing Swiss authorities that this is the case (see post of 25th April on this topic).  In addition to the countries listed above there are reduced rates for pension schemes in the Spain and Norway double taxation treaties that have yet to be ratified. (see post of 14th March)

For Germany the double taxation treaty reduces the withholding tax rate from 15% to 10% for pension schemes, for all other countries the rate is reduced to 0% for UK pension schemes.