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HMRC internal manual

International Manual

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

UK dividends paid to a resident of Italy - portfolio investor

See INTM343510 for a description of the term ‘portfolio investor’.

The convention (see Article 10) provides for payment to the beneficial owner of the dividends of the excess of UK tax credit after retention of 15% of the aggregate of the UK dividend plus the tax credit.

The convention also requires the dividends to be ‘subject to tax’ in Italy. See INTM162090 and INTM350550 for explanation of ‘subject to tax’.

See also INTM343520 about UK dividends paid on or after 6 April 1999.