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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Ghana: Dividends

The Ghanaian tax deducted from dividends at the agreement rate of 15 per cent (or 7.5 per cent where the beneficial owner of the dividend is a company which controls, directly or indirectly, at least 10 per cent of the voting power in the company paying the dividends) qualifies for credit as a direct tax (see INTM164010(c)).

These reduced rates do not apply if the dividends are effectively connected with a business carried on by a permanent establishment or fixed base which the recipient has in Ghana (see INTM153110, fifth sub-paragraph).

A United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power in the Ghanaian company is entitled, under the agreement, to credit for the underlying tax (see INTM164010(d)) (Article 25(1)(b)).