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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Philippines: Dividends

The Philippines tax deducted from dividends paid by a Philippines company at the agreement rate of 25 per cent (15 per cent where 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)).

The reduction to the above rates is not given if the dividends are effectively connected with (see INTM153110 fifth sub-paragraph) a trade or business carried on through a permanent establishment in, or the performance of professional services from a fixed base in, the Philippines (Article 9(5)).

Where the recipient of the dividend is a United Kingdom resident company which controls, directly or indirectly, at least 10 per cent of the voting power in the Philippines company paying the dividend, relief is also due in respect of the underlying tax (see INTM164010(d)) (Article 21(1)(b)).