Announcement 2021-14, page 315.

The competent authorities of the United States and the United Kingdom have entered into a Competent Authority Arrangement under paragraph 3 of Article 26 (Mutual Agreement Procedure) agreeing that U.K. residents may be eligible to qualify as equivalent beneficiaries for purposes of applying the derivative benefits test in paragraph 3 of Article 23 (Limitation on Benefits) of the U.S.-U.K. Income Tax Treaty.