SolvedINTM164500 | UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - Foreign Income - inclusive rates - examples
From HM Revenue & Customs · International Manual
Exceptionally, CTIAA Underlying Tax Group will compute an inclusive rate, that is the underlying rate plus the rate of direct tax scaled down as in the case of dividends paid by a Jamaican company (seeDT10553). For a dividend into the UK this is likely to have been at the request of the company.
An inclusive rate is computed as in the following example
Direct tax = 5%
Agreed rate of underlying tax = 24%
Inclusive rate = 5%(100 - 24) + 24 = 27.8%
If an inclusive rate of tax has been calculated the starting point for the UK measure of the foreign income is the net dividend after deduction of the foreign direct tax.
Example
| £ | |
|---|---|
| Gross dividend | 200,000 |
| Direct tax (5%) | 10,000 |
| Underlying rate | 24% |
| Inclusive rate (5%(100 - 24) +24) | 27.8% |
| Foreign Income computation | £ |
| Net dividend | 180,000 |
| Gross at 27.8% | 69,307 |
| Foreign income | 249,307 |
| Corporation Tax at 30% | 74,792 |
| Less tax credit relief (direct & underlying tax) | 69,307 |
| Net Corporation Tax payable | 5,485 |