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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Moldova: Dividends

The Moldovan tax deducted from dividends at the agreement rate of 10 per cent (5 per cent if the beneficial owner is a United Kingdom company which, directly or indirectly, holds at least 20 per cent of the capital of the company paying the dividend) qualifies for credit as a direct tax (see INTM164010(c)).

However, the dividend will be exempt from tax in Moldova if the United Kingdom beneficial owner is either a company that holds, directly or indirectly, at least 50 per cent of the capital of the Moldovan company paying the dividend and has invested at least £1 million in the capital of that company or is a pension scheme.

The 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 which the recipient has in Moldova.

A United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power of the Moldovan company paying the dividend is entitled, under Article 22(2)(b), to credit for underlying tax (see INTM164010(d)).