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HMRC internal manual

Double Taxation Relief Manual

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

As indicated in DT8602(a), Guernsey tax deducted from a dividend is not admissible for credit under the agreement. It is company tax deducted (see INTM164010(e)) and unilateral relief is not due to a portfolio shareholder (see INTM164010(f)) since the whole of it represents tax which the paying company would have borne if the dividend had not been paid (see conditions of (c)(i) of ICTA88/S790 (5)).

Where a dividend is declared, credit is allowable for underlying tax only in respect of the amount of tax actually paid by the Guernsey company on the particular profits out of which the dividend is paid (see Statement of Practice SP12/93 and INTM164070).