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HMRC internal manual

Double Taxation Relief Manual

Montserrat: Dividends

Credit for such tax is not due to portfolio shareholders (see INTM164010(f)).

Where the dividend is paid to a United Kingdom company which controls, directly or indirectly, at least 10 per cent of the voting power in the Montserrat company paying the dividend, credit may be given for the underlying tax (see INTM164010(d)).