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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Tuvalu: Dividends

The Tuvalu tax deducted from a company dividend paid by a Tuvalu company is company tax (see INTM164010(e)). Credit for such tax is not due to portfolio shareholders (see INTM164010(f)). Where a Tuvalu company pays a dividend to a United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power in the Tuvalu company credit is also due for the underlying tax (see INTM164010(d)).