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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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Double Taxation relief Manual: Guidance by country: Azerbaijan: Dividends

The Azerbaijan tax deducted from dividends at the agreement rate of 15 per cent (or 10 per cent where the beneficial owner of the dividends is a United Kingdom resident company controlling directly or indirectly not less than 30 per cent of the voting power in the company paying the dividend or a United Kingdom resident company which has invested at least 100,000 US dollars (or the equivalent amount in the currency of either Contracting State) in the share capital of the company paying the dividends at the date of payment of the dividends) 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 (see INTM153110 fifth sub-paragraph) with a business carried on by the United Kingdom resident recipient through a permanent establishment in Azerbaijan or with a fixed base in Azerbaijan from which he performs professional services.

Where an Azerbaijan 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 Azerbaijan company, credit may also be given for the underlying tax (see INTM164010(d)) Article 22(1)(b).