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HMRC internal manual

Double Taxation Relief Manual

India: Dividends

From 1 June 1997 India abolished withholding taxon dividends, and companies became liable to an additional tax upon distribution of their profits. Where an Indian company pays a dividend to a United Kingdom company which controls, directly or indirectly, at least 10 per cent of the voting power in the Indian company, credit may also be given for the underlying tax (see INTM164010 (d Article 24(1)(b)).

The additional tax on distributed profits only qualifies for relief as underlying tax INTM164010(d)).