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HMRC internal manual

Double Taxation Relief Manual

Bolivia: Dividends

The Bolivian tax deducted from dividends at the agreement rate of 15 per cent qualifies for credit as a direct tax. This reduced rate does not apply if the dividends are effectively connected (see INTM153110) with a business carried on through a permanent establishment or fixed base which the recipient has in Bolivia.

A United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power of the Bolivian company paying the dividend is entitled, under Article 23(1)(b), to credit for underlying tax (see INTM164010).