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HMRC internal manual

Double Taxation Relief Manual

Russia: Dividends

Russian Federation tax deducted from dividends at the agreement rate of 10 per cent qualifies for credit as a direct tax (see INTM164010(c)). This reduced rate does not apply if the dividends are effectively connected (see ITM153110 fifth sub-paragraph) with a business carried on through a permanent establishment or fixed base which the recipient has in the Russian Federation.

A United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power of the Russian Federation company paying the dividend is entitled, under Article 22(1)(b), to credit for underlying tax (see INTM164010(d)).