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HMRC internal manual

Double Taxation Relief Manual

Lesotho: Dividends

The Lesotho tax deducted from dividends at the agreement rate of 10 per cent qualifies for credit as a direct tax (see INTM164010 (c)). This reduced rate does not apply if the dividends are effectively connected (see INTM153110, fifth sub-paragraph) with a business carried on through a permanent establishment or fixed base which the recipient has in Lesotho.

A United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power of the Lesotho company paying a dividend is entitled, under Article 23(1)(b), to credit for underlying tax (see INTM164010 (d)).