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HMRC internal manual

International Manual

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DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland

UK dividends paid to a resident of Ireland - portfolio investor

The convention as amended makes no provision for payment of tax credit to portfolioinvestors in respect of UK dividends paid on or after 6 April 1999. See INTM343520 for a definition of the term ‘portfolioinvestor’.

In respect of UK dividends paid before 6 April 1999, the convention provides for paymentof the excess of UK tax after retention of 15% of the aggregate (of net UK dividend plustax credit) to the beneficial owner of the dividend who is a resident of Ireland.

And also in respect of dividends paid before 6 April 1999, the convention provides forpayment of the full amount of tax credit to a claimant who qualifies as either“exempt approved” or “100% exempt” under the (Irish) TaxesConsolidation Act 1997. You will find more information on such bodies at INTM353595.