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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Taiwan: Dividends

The Taiwanese 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 is not given if the dividends are effectively connected (see INTM153110 fifth sub-paragraph) with a business carried on by the United Kingdom resident recipient through a permanent establishment in Taiwan or with a fixed base in Taiwan from which they perform professional services.

Where a Taiwan company pays a dividend to a United Kingdom company which controls directly or indirectly not less than 10 per cent of the voting power in the Taiwanese company, credit may also be given for the underlying tax (see INTM164010(d)) (Article 22(1)(b)).