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HMRC internal manual

International Manual

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

UK dividends paid to a resident of Malta (Article 10) - portfolio investor

The Double Taxation Convention provides for payment of the excess of UK tax creditafter retention of 15% of the aggregate of the UK dividend plus the tax credit. But fordividends paid since 6 April 1999 there is no tax credit to pay. See INTM343520.

See INTM343520 for an explanation of the term “portfolioinvestor”.

There is no provision for payment of tax credit to for example, companies, executors ortrustees. Beneficiaries of trusts who are individuals can claim for income that isdistributed to them.