International Manual

INTM164040 - UK residents with foreign income or gains: dividends: Portfolio shareholders

The elimination of double taxation Articles (credit Articles) in a double taxation agreement generally provide that the UK resident portfolio shareholder is entitled to tax credit relief for foreign direct tax on a dividend received from a foreign company. There is no entitlement to relief for underlying tax or company tax deducted.

This is because the Article expressly prohibits the allowance of credit. For example, where the dividend Article is the type referred to in INTM164020 sub-head (a), the credit Articles are worded in terms of `바카라 사이트�. the credit shall only take into account such tax in respect thereof as is additional to any tax payable by the company on the profits out of which the dividend is paid and is ultimately borne by the recipient without reference to any tax so payable바카라 사이트�.

Where the dividend Article is the type referred to in INTM164020 sub-head (b) the credit Articles are worded as in Article 21(5)(a) of the UK/Netherlands agreement , `(excluding in the case of a dividend, tax payable in respect of the profits out of which the dividend is paid)바카라 사이트�. If using the HMRC Intranet, the agreement can be viewed through the 바카라 사이트淣ew treaties/protocols in force바카라 사이트� link on the sidebar. On the HMRC web-site, searching for 바카라 사이트淭reaties in force Netherlands바카라 사이트� will provide a link to the treaty.