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Chapter INTM164070

Document Cited in Related
Vincent
Published date09 April 2016
Record NumberINTM164070
CourtHM Revenue & Customs
IssuerHM Revenue & Customs

Some countries outside the UK operate a `company tax deducted’ system whereby, when a dividend is paid, tax is accounted for at the standard rate of tax on company profits. Where an agreement contained a provision allowing relief to direct investors for underlying tax, it was previously the practice in the UK to allow credit at the rate of company tax deducted or at the rate of tax paid by the non-resident company on its profits (the actual underlying rate), whichever was the greater. Dividends paid by companies resident in Belize, the Gambia, Malaysia and Singapore were treated in this way.

This meant that in some cases relief could be given for more foreign tax than had actually been...

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