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HMRC internal manual

International Manual

UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - old agreements

Two double taxation agreements made before the passing of Finance Act 1965 remain which give tax credit relief for underlying tax to both companies and individuals : Burma (Myanmar) and St. Christopher (St. Kitts) - Nevis (see INTM164050).

The Underlying Tax Group, Yorke House, Nottingham will compute the rates of foreign tax in respect of dividends paid during the period in which these agreements remain in force. Applications should be made to them in the usual way under INTM164440 for the rate of foreign tax applicable to the dividend in question.