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HMRC internal manual

Double Taxation Relief Manual

Solomon Islands: Dividends

Dividends are deductible in computing a Solomon Islands company’s profits chargeable to tax. Article 6(4) of the agreement prevents the Solomon Islands from charging a United Kingdom resident recipient of a Solomon Islands company dividend with any tax on that dividend which is additional to the tax charged on the company’s profits.

Where a Solomon Islands company pays a dividend to a United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power in the Solomon Islands company, credit is due for the underlying tax (see INTM164010 (d)) .