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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Mongolia: Dividends

The Mongolian tax deducted from dividends at the agreement rate of 15 per cent (5 per cent if the recipient is a United Kingdom company which controls, directly or indirectly, at least 10 per cent of the voting power in the company paying the dividend) 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 Mongolia.

A United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power of the Mongolian company paying the dividend is entitled, under Article 24(1)(b), to credit for underlying tax (see INTM164010(d)).