CTM34270 | Residence: non-resident companies: distributions received

From HM Revenue & Customs · Company Taxation Manual

UK company distributions received by non-resident companies do not constitute franked investment income (see ) and are specifically excluded from the income of a branch or agency (see (b) of ). In principle, they are within the charge to IT but ITTOIA05/S399 (2) - qualifying distributions received by persons not entitled to tax credits, and - non qualifying distributions, provide that income tax is treated as having been paid at the dividend ordinary rate and hence there is no liability

As regards cases covered by Double Taxation Agreements see .