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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Malta: Dividends

Maltese tax deducted from a dividend paid by a Maltese company is company tax deducted (see INTM164010). Credit for such tax is not due to portfolio shareholders.

Where the recipient of a dividend is a United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power in the Maltese company paying the dividend, credit is due for the underlying tax paid by the Maltese company on the profits out of which the dividend is paid (see Statement of Practice SP12/93 and INTM164070).