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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Swaziland: Dividends

Swaziland tax deducted from a dividend paid by a Swaziland company at the agreement rate of 15 per cent qualifies for credit as a direct tax (see INTM164010 (c)).

The reduction to the above rate is not given if the dividend is effectively connected with (see INTM153110 fifth sub-paragraph) a business carried on by the recipient through a permanent establishment in Swaziland.

Where a dividend is paid to a United Kingdom resident company which controls, directly or indirectly, at least 10 per cent of the voting power in the Swaziland company, credit may also due for the underlying tax (see INTM164010 (d)).