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HMRC internal manual

International Manual

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

UK dividends paid to a resident of Japan (Article 11) - portfolio investor

The double taxation convention provides for payment of the excess of UK tax creditafter retention of 15% of the aggregate of UK dividend plus taxcredit.But for dividends paid since 6 April 1999 there is no tax credit to pay. See INTM343520.

There is no provision for the payment of tax credit to companies which own more than 10%of the voting power in the company paying the dividend.