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HMRC internal manual

Double Taxation Relief Manual

India: Underlying Tax

 (1) Documents needed to support the underlying tax claim

The accounts showing the profits out of which the dividend was paid and the first page of the Income Tax Return, which show the tax assessed will be required by the Underlying Tax Group. If the Tax Return is not available, the company’s tax computation which shows the calculation of income tax payable should be sent instead.


(2) Dividend distribution tax

Relevant Profits are reduced by the dividend tax provision shown in the company’s profit & loss account.

The dividend distribution tax is admissible as an underlying tax,which attaches to the dividend:


Dividend R’s     100,000,000  
Underlying tax 50,000,000      


  Dividend Distribution tax  60,000,000


 (3) Reserves


Relevant profits are reduced by transfers to:

Debenture Redemption Reserve

Development Allowance Reserve

Export Incentive Reserve

Investment Allowance Reserve

Investment Allowance (Utilised) Reserve

Tourism Reserve


 (4) Spared taxes

A copy of the certificate granting tax spared status and the relevant page(s) of the company’s tax computation showing the spared taxes should be sent to the Underlying Tax Group.