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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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UK residents with foreign income or gains: dividends: Unilateral relief - underlying tax - chains of companies

TIOPA10/S65

Section 65 extends relief under Section 63 to chains of companies as defined by S64. Credit relief is available to a UK company receiving a dividend from a foreign company that it controls directly or indirectly, or is a subsidiary of a company which controls directly or indirectly, 10 per cent of the voting power in the shares of the foreign company paying the dividend and that company in turn controls directly or indirectly, or is a subsidiary company of a company which controls, 10 per cent or more of the voting power in the third company and so on. Relief is given for the underlying tax for third and successive companies. Detailed instructions on Section 65 are given in INTM167380 onwards.