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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Greece: Dividends

There is no dividend Article in the agreement and domestic law will therefore apply subject to the provisions of the EU Parents/Subsidiary directive.

The agreement does not provide for credit for underlying tax (see INTM164010(d)), but where a United Kingdom company controls, directly or indirectly, not less than 10 per cent of the voting power in the Greek company paying the dividend, credit is due unilaterally for such underlying tax.