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HMRC internal manual

International Manual

Foreign tax paid on trade income: limitation on credit: Transitional rule

There was a transitional rule for the period from 16 March 2005 to 31 December 2005, which applied to foreign tax paid in respect of dividend income. For this type of foreign tax payment, nothing in the legislation shall deny credit relief for more than half of the foreign tax paid by any person in respect of dividends received in this period.