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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Luxembourg: Underlying Tax

(1) Documents needed to support the underlying tax claim.

The accounts showing the profits out of which the dividend was paid and pages 1 and 2 of the tax return showing the tax assessed will be required by the Underlying Tax Group.

(2) Legal reserve

Relevant profits are reduced by transfers of 5% of annual profit until the reserve reaches 10% of share capital.