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HMRC internal manual

International Manual

HM Revenue & Customs
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DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

UK dividends paid to a resident of Luxembourg - portfolio investor

See INTM343520 for a definition of a portfolio investor.

Article 10 provides for payment of the excess of UK tax after retention of 15% of theaggregate (of net UK dividend plus tax credit) to the beneficial owner of the dividend whois a resident of Luxembourg.