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HMRC internal manual

International Manual

HM Revenue & Customs
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UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - 10% control cases

Where relief for underlying tax is available to a UK company which controls 10% (see INTM164360) of the voting power in a foreign company under:

a) TIOPA10/S14 and TIOPA 2010/S65 (as extended by ESC/C1 (b) for insurance companies for accounting periods beginning before 1 April 2000 - see the General Insurance Manual and Life Assurance Manual) or

b) an equivalent provision in a double taxation agreement negotiated or amended after the passing of FA 1965,

the foreign rate will be determined by Underlying Tax Group, Yorke House, Nottingham.

See INTM164440 for instructions on procedure where a claim to relief for underlying tax is made.