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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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New Zealand: Dividends

The New Zealand tax deducted from dividends at the rate of 15 per cent specified in the agreement qualifies for credit as a direct tax (see INTM164010(c)).

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 New Zealand company paying the dividend, credit may also be given for the underlying tax (see INTM164010 (d)).