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Official guidance
International Manual

INTM164000 · Double Taxation Relief: UK residents with foreign income or gains - dividends

  • INTM164010 · UK residents with foreign income or gains: dividends: Foreign dividends - glossary
  • INTM164020 · UK residents with foreign income or gains: dividends: Dividend articles in double taxation agreements
  • INTM164030 · UK residents with foreign income or gains: dividends: EC Directive
  • INTM164040 · UK residents with foreign income or gains: dividends: Portfolio shareholders
  • INTM164050 · UK residents with foreign income or gains: dividends: Portfolio shareholders - exceptions
  • INTM164060 · UK residents with foreign income or gains: dividends: Direct investors - underlying tax
  • INTM164070 · UK residents with foreign income or gains: dividends: Tax deducted
  • INTM164080 · UK residents with foreign income or gains: dividends: Split rate taxes
  • INTM164090 · UK residents with foreign income or gains: dividends: Dividend stripping
  • INTM164100 · UK residents with foreign income or gains: dividends: Underlying tax
  • INTM164110 · UK residents with foreign income or gains: dividends: Underlying tax - rate boosting
  • INTM164120 · UK residents with foreign income or gains: dividends: Underlying tax - computation of relevant profits
  • INTM164130 · UK residents with foreign income or gains: dividends: Underlying tax - dividend resolutions
  • INTM164140 · UK residents with foreign income or gains: dividends: Underlying tax - minimising foreign tax paid
  • INTM164150 · UK residents with foreign income or gains: dividends: Underlying tax - groups taxed as a single entity overseas
  • INTM164151 · UK residents with foreign income or gains: dividends: Consolidated tax calculation - joiners and leavers
  • INTM164155 · UK residents with foreign income or gains: dividends: Tax deductions for dividends
  • INTM164156 · UK residents with foreign income or gains: dividends: Accounts deductions for dividends
  • INTM164160 · UK residents with foreign income or gains: dividends: Underlying tax: reserves
  • INTM164170 · UK residents with foreign income or gains: dividends: Underlying tax - pre-merger profits - dividends paid to the UK before 21 March 2000
  • INTM164180 · UK residents with foreign income or gains: dividends: Underlying tax - pre-merger profits - dividends paid to the UK on or after 21 March 2000
  • INTM164190 · UK residents with foreign income or gains: dividends: Underlying tax - imputation systems
  • INTM164200 · UK residents with foreign income or gains: dividends: Underlying tax - insurance companies
  • INTM164210 · UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001 - background and overview
  • INTM164215 · UK residents with foreign income or gains: dividends: Shares treated as loan relationships
  • INTM164220 · UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001 - the mixer cap
  • INTM164230 · UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001 - the mixer cap - examples and responsibility
  • INTM164235 · UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 2 December 2004 - the ADP mixer cap
  • INTM164240 · UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001 - eligible unrelieved foreign tax - overview
  • INTM164250 · UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001 - eligible unrelieved foreign tax - Case A
  • INTM164260 · UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001 - eligible unrelieved foreign tax - Case B
  • INTM164270 · UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001: onshore pooling
  • INTM164280 · UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001: ADP dividends
  • INTM164290 · UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001 - ADP dividends - example
  • INTM164300 · UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001 - dividends barred from on-shore pools
  • INTM164310 · UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001: eligible unrelieved foreign tax - order of carry back
  • INTM164320 · UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001: eligible unrelieved foreign tax - order of use
  • INTM164330 · UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001: eligible unrelieved foreign tax - group surrender
  • INTM164340 · UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001 - eligible unrelieved foreign tax - group surrender - dual-resident company
  • INTM164350 · UK residents with foreign income or gains: dividends: Unilateral relief - direct tax
  • INTM164360 · UK residents with foreign income or gains: dividends: Unilateral relief - underlying tax
  • INTM164370 · UK residents with foreign income or gains: dividends: Unilateral relief - underlying tax - chains of companies
  • INTM164380 · UK residents with foreign income or gains: dividends: Unilateral relief - banks
  • INTM164390 · UK residents with foreign income or gains: dividends: Unilateral relief - insurance companies
  • INTM164400 · UK residents with foreign income or gains: dividends
  • INTM164410 · UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - old agreements
  • INTM164420 · UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - 10% control cases
  • INTM164430 · UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - insurance companies
  • INTM164440 · UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - procedure
  • INTM164443 · UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - procedure - information requirements
  • INTM164450 · UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - UTG and CTSA
  • INTM164460 · UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - information provided by UTG
  • INTM164470 · UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - Foreign Income computations - dividends received on or after 31 March 2001
  • INTM164480 · UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - Case V computations - dividends received on or after 31 March 2001 with withholding tax
  • INTM164490 · UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - Foreign Income - standard cases - example
  • INTM164500 · UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - Foreign Income - inclusive rates - examples
  • INTM164510 · UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - Foreign Income - company tax deducted - example
  • INTM164515 · UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - Foreign Income - tax spared - example
  • INTM164520 · UK residents with foreign income or gains: dividends: Paying agents
  • INTM164530 · UK residents with foreign income or gains: dividends: Paying agents - provisional credit
  • INTM164540 · UK residents with foreign income or gains: dividends: Paying agents - examples
  1. Double Taxation Relief: UK residents with foreign income or gains - dividends: contents
  2. UK residents with foreign income or gains: dividends: Split rate taxes

INTM164080 | UK residents with foreign income or gains: dividends: Split rate taxes

From HM Revenue & Customs · International Manual

In addition, some countries tax company profits at a different rate if they are distributed. An additional levy may be charged or part of a higher initial tax refunded. This is known as a split rate tax system.

Dividends paid to the UK on or after 21 March 2000 that have been subject to a split rate of tax are covered by SP3/01. This effectively allocates all the additional tax or reduction to the portion of the profits represented by the dividend, rather than spreading it over the whole profits for the period.

The amount of overseas tax available for credit relief will be calculated by CTIAA Underlying Tax Group, Nottingham. Any case where underlying tax is claimed should be referred to them with the information requested at INTM164440.

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