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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Guidance by country: Armenia: dividends

Where the beneficial owner of a dividend is a resident of the United Kingdom, withholding tax at a rate not exceeding 15% is payable if the dividend is paid out of the property income of an investment vehicle equivalent to a United Kingdom Real Estate Investment Trust.

Dividends are taxable in Armenia at a rate not exceeding 5% where the United Kingdom beneficial owner is a company which controls at least 25 per cent of the company paying the dividend (unless this company is a property investment vehicle) and has invested at least £1 million in the share capital of this company at the date of payment of the dividend.

Dividends are exempt from tax in Armenia if the United Kingdom beneficial owner of the dividends is a pension scheme.

In respect of all other United Kingdom recipients, withholding tax is payable at a rate not exceeding 10 per cent.

The reduced rates provided by the treaty are not given if the dividend is effectively connected (see INTM153110 eighth sub-paragraph) with a permanent establishment which the United Kingdom resident recipient has in Armenia.