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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: Determination of rates of foreign underlying tax - procedure - information requirements

INTM164443 | UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - procedure - information requirements

From HM Revenue & Customs · International Manual

A request to agree the underlying tax rate under INTM164440 should be sent to CTIAA Underlying Tax Group, Yorke House, Nottingham.

The memo should provide the following documents and information:

  • Foreign Income computations and underlying tax calculations (from the computations).

  • The name and address of the agent or company officer with whom UTG should correspond.

  • Details of the percentage shareholding the UK company has in the dividend paying company.

  • If held, copies of the dividend paying company’s accounts, tax documentation and dividend resolution.

  • UTG does not require Officers to open enquiries at the submission stage, but please advise if you have opened an enquiry for other reasons.

Officers should not enter into correspondence with the claimant company or its agents about the underlying tax calculation. UTG will ask the company or its agents for the material required to establish the underlying tax rate, if necessary. See INTM164460 for the information that UTG will supply Officers and INTM164470 onwards for examples of computations.

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