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HMRC internal manual

Double Taxation Relief Manual

Ivory Coast: Dividends

The Ivory Coast tax deducted from dividends at the agreement rate of 15 per cent (18 per cent if the dividend is paid by an Ivory Coast company which is exempt from tax on its profits there or does not pay tax at the normal rates) qualifies for credit as a direct tax (see INTM164010(c)).

The reduction in the above rates is not given where the dividend is effectively connected with (see INTM153110 fifth sub-paragraph.) a permanent establishment or fixed base which the United Kingdom resident recipient has in the Ivory Coast (Article 10(4)).

Where the recipient of the dividend is a United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power in the Ivory Coast company paying the dividend, credit may also be given for the underlying tax (see INTM164010(d)) (Article 23(1)(b)).