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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Botswana: Dividends

The Botswana tax deducted from dividends at the agreement rate of 5 or 12 per cent qualifies for credit as a direct tax (see INTM164010(c)). The reduction to the above rate is not given where the dividend is effectively connected (see INTM153110 fifth sub-paragraph) with a business carried on by the United Kingdom resident recipient through a permanent establishment in Botswana or with a fixed base in Botswana from which he performs professional services.

Where a Botswana company pays a dividend to a United Kingdom company which controls, directly or indirectly, at least 10 per cent of the voting power in the Botswana company, credit may also be given for the underlying tax (see INTM164010(d)) (Article 23(2)(b)).