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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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UK residents with foreign income or gains: corporation tax: Dividends: withholding tax

Give tax credit relief for the direct tax (see INTM164010 paragraph (c)) charged on a dividend. This is usually described as withholding tax. Where the dividend is paid by a company which is a resident of a country with which the UK has a double taxation agreement, the relief should be limited to the lower of the domestic rate of withholding tax or the rate specified in the dividend article in the agreement (see INTM164020 sub-head (b). These rates are given in the relevant country section from DT2100 onwards.

Certain dividends paid to the UK on or after 31st March 2001 and before 1 July 2009 will be pooled and may utilise eligible unrelieved foreign tax (EUFT) that has arisen elsewhere. See INTM164230 onwards.