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HMRC internal manual

International Manual

UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - procedure - information requirements

A request to agree the underlying tax rate under INTM164440 should be sent to CTIAA Underlying Tax Group, Yorke House, Nottingham.

The memo should provide the following documents and information:

  • Foreign Income computations and underlying tax calculations (from the computations).
  • The name and address of the agent or company officer with whom UTG should correspond.
  • Details of the percentage shareholding the UK company has in the dividend paying company.
  • If held, copies of the dividend paying company’s accounts, tax documentation and dividend resolution.
  • UTG does not require Officers to open enquiries at the submission stage, but please advise if you have opened an enquiry for other reasons.

Officers should not enter into correspondence with the claimant company or its agents about the underlying tax calculation. UTG will ask the company or its agents for the material required to establish the underlying tax rate, if necessary. See INTM164460 for the information that UTG will supply Officers and INTM164470 onwards for examples of computations.