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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Malta: Underlying Tax

(1) Documents needed to support the underlying tax claim

The accounts showing the profits used to pay the dividend and the notice of assessment showing the tax payable on these profits will be required by the Underlying Tax Group.

(2) Spared tax

The calculation of tax spared prepared by the Maltese company’s accountants should be sent to the Underlying Tax Group together with the certificate granting tax sparing status.

(3) Company tax deducted

Maltese dividends do not suffer withholding tax as such. The amount shown on the dividend voucher is notional company tax deducted (CTD) which is not available for credit for dividends paid on or after 27 July 1993. The underlying tax rate is calculated using the accounts profits and the assessed tax.