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HMRC internal manual

International Manual

UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - information provided by UTG

The UTG will consider the rate of underlying tax arising on a foreign dividend following a submission under INTM164440 or a request from the company. It will then supply to the relevant office within HMRC:

a) Confirmation of the amount of the dividend, in the appropriate foreign currency;

b) The actual rate of underlying tax paid on this (to calculate the amount assessable as foreign income);

c) For dividends paid to the UK on or after 31 March 2001, a capped rate of underlying tax if the mixer cap has restricted the amount of foreign tax credit due;

d) If appropriate:

  • the amount of Eligible Unrelieved Foreign Tax (EUFT)arising on a mixed dividend or;
  • a reminder that EUFT arises on an unmixed dividend and this should be calculated by the local tax office

INTM164470 onwards give examples of computations.

The legislation relating to EUFT was repealed for distributions paid on or after 1 July 2009.