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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Zimbabwe: Dividends

The Zimbabwean tax deducted from dividends at the agreement rate of 20 per cent (5 per cent if the recipient is a United Kingdom resident company controlling, directly or indirectly, at least 25 per cent of the voting power in the Zimbabwean company) qualifies for credit as a direct tax (see INTM164010 (c)).

The reductions to the above rates are not given if the dividends are effectively connected with (see INTM153110 fifth sub-paragraph) a business carried on by the recipient through a permanent establishment or a fixed base from which he performs independent personal services, in Zimbabwe.

Where the dividend is paid to a United Kingdom resident company controlling, directly or indirectly, at least 10 per cent of the voting power in the Zimbabwe company, credit may also be given for the underlying tax (Article 23(1)) (see INTM164010 (d)).