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HMRC internal manual

Double Taxation Relief Manual

Romania: Underlying Tax

 (1) Documents needed to support the underlying tax claim

The accounts showing the profits out of which the dividend was paid and the tax return showing the final liability to tax on those profits will be required by the Underlying Tax Group

 (2) Reserves

Relevant profits are reduced by transfers to the legal reserve of 5% of net profits until the reserve equals 20% of share capital.