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HMRC internal manual

Double Taxation Relief Manual

Fiji: Dividends

Fijian tax deducted from dividends at the agreement rate of 15 per cent qualifies for credit as a direct tax (see INTM164010(c)).

The reduction to the above rate is not given if the dividend is effectively connected with (see INTM153110 fifth sub-paragraph) a business carried on by the United Kingdom resident recipient through a permanent establishment in Fiji.

Where a dividend is paid to a United Kingdom company which controls, directly or indirectly, at least 10 per cent of the voting power in the Fijian company paying the dividend, credit is also due for the underlying tax (Article 22(3)(b) and see INTM164010(d)).