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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Uganda: Dividends

The rate of Ugandan tax on dividends paid by a Ugandan company to a United Kingdom-resident shareholder who is the beneficial owner of the dividends is limited to a maximum of 15 per cent (Article 10(2)).

If any Ugandan tax is charged on a dividend it will qualify for relief as a direct tax (see INTM164010(c)). The restriction of the withholding tax to a maximum of 15 per cent does not apply where the dividend is effectively connected with (see INTM153110, fifth sub-paragraph) a permanent establishment or fixed base which the beneficial owner of the dividends has in Uganda (Article 10(4)).