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HMRC internal manual

Double Taxation Relief Manual

Fiji: Underlying Tax

(1) Documents needed to support the underlying tax claim

The accounts showing the profits used to pay the dividend and the final notice of assessment taxing these profits will be required by the Underlying Tax Group.

(2) Spared tax

Credit for spared tax is available in accordance with Article 22 (2) of the agreement. The calculation of tax spared prepared by the Fiji company’s accountants should be sent to the Underlying Tax Group together with the certificate granting tax sparing status.