DT17754 - 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)).