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HMRC internal manual

Double Taxation Relief Manual

Sudan: Dividends

The rate of Sudan tax on dividends paid by a Sudan company is limited to 15 per cent, but, where such dividends are exempt from Sudan tax when paid to non-residents, they are exempt from Sudan tax when received by a resident of the United Kingdom (Article 10(2) and (3)).

If any Sudan tax is charged on a dividend, it will qualify for relief as a direct tax (see INTM164010(c)). Where a dividend is paid by a Sudan company to a United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power in the Sudan company, relief is also due for the underlying tax (see INTM164010 (d)).