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HMRC internal manual

International Manual

UK residents with foreign income or gains: dividends: Unilateral relief - banks


TIOPA10/S70 limits the relief for underlying tax on certain dividends received by UK banks. These are dividends where the underlying tax is or includes foreign tax payable by reference to interest or dividends earned or received in the course of a company’s business and TIOPA10/S44 would apply to that company if it were resident in the UK.

Information about these provisions can be found at INTM168200. They are administered by the Underlying Tax Group at Nottingham, but Tax Specialists should ensure the UTG is aware of any such company amongst the overseas subsidiaries of a UK company.