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HMRC internal manual

International Manual

UK residents with foreign income or gains: dividends: Accounts deductions for dividends

The amount of relief for underlying tax is calculated according to the rules contained in TIOPA10/S57. In some situations, a company may pay a dividend, and make a deduction in arriving at relevant profits calculated by reference to that dividend. Where this is the case, that dividend cannot represent a proportion of relevant profits and no relief is available for underlying tax.