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HMRC internal manual

General Insurance Manual

Double Taxation Relief: background: residence and similar certificates


The UK’s DTCs usually limit the rate of tax that may be imposed on dividends and interest by the other Contracting State. A typical rate is 15% on dividends from portfolio investments, but the rate varies from treaty to treaty. Interest is often paid without any withholding tax under the terms of treaties, but in some cases there are rates of 10%.

Relief is not available as credit for any tax suffered by a company in excess of the treaty rate – see INTM161250. Any tax suffered by a company in excess of an applicable treaty rate should be reclaimed by the company from the other state. Inspectors are often required to sign certificates or to issue letters to enable companies to receive income with reduced or no withholding tax in accordance with a treaty, or to enable a company to reclaim tax. See INTM162030.