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HMRC internal manual

International Manual

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

UK dividends paid to a resident of New Zealand (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 the UK dividend plus the tax credit. But fordividends paid since 6 April 1999 there is no tax credit to pay. See INTM343520.

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 which isdistributed to them.