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HMRC internal manual

International Manual

UK residents with foreign income or gains: dividends: Portfolio shareholders - exceptions

As at January 2010, two double taxation agreements which came into force before FA65 have not been renegotiated which provide that individuals and companies controlling less than 10 per cent of the voting power in the foreign company paying the dividend are also entitled to relief for the underlying tax.

The two agreements are those with Burma (Myanmar) and St. Christopher (St. Kitts) - Nevis. See INTM164410 for the procedure to use.