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HMRC internal manual

Double Taxation Relief Manual

Kenya: Dividends

The Kenyan tax deducted from dividends at the agreement rate of 15 per cent qualifies for credit as a direct tax (see INTM164010(c)).

The reduction to this rate is only given where the recipient is subject to United Kingdom tax (see INTM162020) on the dividend in question and it is not given where the dividend is effectively connected (see INTM153110 fifth sub-paragraph) with a business carried on by the recipient through a permanent establishment in Kenya (Articles 11(4) and (7)).

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 Kenyan company paying the dividend, credit may also be given for the underlying tax (see INTM164010(d)) (Article 26(l)(b).