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HMRC internal manual

International Manual

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

UK dividends paid to a resident of Switzerland - direct investor

Article 10 of the Convention

Payment of UK tax credit to direct investor companies is half the tax credit less 5% ofthe dividend and half the tax credit (see INTM343540).

Dividend stripping provisions

Article 10(3)(d)(i) as substituted by protocol SI1982/714 applies dividend strippingprovisions (see INTM343550). A resident of Switzerland is notentitled to a tax credit unless he can show that the shareholding was acquired for genuinecommercial reasons or in the ordinary course of business and it was not the main object ofone of the main objects to obtain entitlement to a tax credit.