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HMRC internal manual

International Manual

Double Taxation Agreements: Spain: Income from a UK source paid to a resident of Spain - UK dividends paid to a resident of Spain (Article 10)

The double taxation convention provides for payment of the excess of UK tax credit after retention of 15% of the aggregate of UK dividend plus tax credit. 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 that own at least 10% of the voting power in the company paying the dividend.