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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Jersey: Dividends

As indicated in DT10751(a), Jersey tax deducted from a dividend is not admissible for credit under the agreement. It is company tax deducted (see INTM164010(e)) and unilateral relief is not due to a portfolio shareholder (see INTM164010(f)) since the whole of it represents tax which the paying company would have borne if the dividend had not been paid (see conditions of ICTA88/S790 (5) (c)(i) ).