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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Isle of Man: Dividends

As indicated in DT9951(a), Isle of Man tax deducted from a dividend is not admissible for credit under the agreement. Although such tax is a direct tax (see INTM164010 (c)), 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. Unilateral relief is only due when the recipient is a United Kingdom company controlling, directly or indirectly, or is a subsidiary of a company which controls, directly or indirectly, not less than 10 per cent of the voting power in the Isle of Man company paying the dividend.