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HMRC internal manual

International Manual

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HM Revenue & Customs
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UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - procedure

Where a claim to relief for underlying tax is made in `control’ cases (see INTM164420) the rate must be agreed by CTIAA Underlying Tax Group (UTG) in Nottingham.

A dividend coming into the UK may be composed of several and in some cases many elements. Quantifying some of these will be dependent on foreign accounting or taxation rules and the UK legislation in this area is also complex.

So all underlying tax rates claimed should be referred to the UTG. They will then carry out the risk assessment on that aspect of the return.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000) INTM164443(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)  

UTG encourages groups to submit their ULT calculations to it directly. The information required is set out at INTM164443.

UTG will advise in general terms on areas where there is doubt as to how principles should be applied before a dividend is paid. Requests for advice should be referred to UTG and will be dealt with in accordance with COP 10.

Where groups do not submit their ULT calculations directly to UTG, the tax office should submit them with the information set out at INTM164443.