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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: Paying agents - examples

INTM164540 | UK residents with foreign income or gains: dividends: Paying agents - examples

From HM Revenue & Customs · International Manual

These examples apply for payments up to April 2001. The paying agent scheme was abolished from April 2001.

Example 1 - Where no adjustment is needed

The person’s marginal rate on the foreign dividend is the lower rate, the tax credit relief due is less than the tax at the marginal rate and the paying agent has deducted UK Income Tax at the lower rate less provisional credit for the foreign tax.

---£
Gross foreign dividend--100.00
Less foreign withholding tax at 15%--15.00
---85.00
Less UK tax at 5% (that is lower rate 20% less credit at 15% on 100)--5.00
Amount received by shareholder--80.00
Claimant’s total income consists of---
--£-
UK untaxed interest-4,000-
Foreign dividend-100-
--4,100-
PA due = 3,445---
-£--
Total income4,100--
Less PA3,445--
-655--
Tax thereon (655 at 20%)--131.00
--£-
Total income-4,100-
Less foreign income-100-
Reduced total income-4,000-
Less PA-3,445-
--555-
Tax thereon (555 at 20%)--111.00
Tax at marginal rate on foreign dividend--20.00
Tax on foreign dividend (100 at 20%)--20.00
Less credit allowable--15.00
---5.00
Less UK tax deducted by paying agent--5.00
No adjustment needed--NIL

Example 2 - Where a repayment is due

Tax at the person’s marginal rate on the foreign dividend is less than the credit relief due and the provisional credit allowed by the paying agent.

--£
Gross foreign dividend-100.00
Less foreign withholding tax at 15%-15.00
--85.00
Less UK tax at 5% (that is lower rate 20% less credit at 15% on 100)-5.00
Amount received by shareholder-80.00
Claimant’s total income consists of--
-£-
UK untaxed interest3,400-
Foreign dividend100-
-3,500-
PA due = 3,445--
Total income3,500-
Less PA3,445-
-55-
Tax thereon (55 at 20%)-11.00
Total income3,500-
Less foreign income100-
Reduced total income3,400-
Less PA3,400-
-NIL-
Tax thereon-NIL
Tax at marginal rate on foreign dividend-11.00
Tax on foreign dividend (at marginal rate)-11.00
Less credit allowable-11.00
--NIL
UK tax deducted by paying agent-5.00
Repayment due-5.00
The unrelieved foreign tax of 4.00 (15.00 - 11.00) is not repayable.--

The unrelieved foreign tax of 4.00 (15.00 - 11.00) is not repayable.

Example 3 - Further tax due

Tax at the person’s marginal rate on the foreign dividend is greater than the credit relief due and the provisional credit allowed by the paying agent.

---£
Gross foreign dividend--100.00
Less foreign withholding tax at 15%--15.00
---85.00
Less UK tax at 5% (that is lower rate 20% less credit at 15% on 100)--5.00
Amount received by shareholder--80.00
Claimant’s total income consists of---
--£-
UK trading profits-30,000-
Foreign dividend-100-
--30,100-
PA due = 5,910---
Total income30,100--
Less PA5,910--
-24,190--
Tax thereon2,500 at 20%-500.00
Trading profits21,200 at 25%-5,300.00
-390 at 40%-156.00
Foreign dividend100 at 40%-40.00
---5,996.00
Total income-30,100-
Less foreign income-100-
Reduced total income-30,000-
Less PA-5,910-
--24,090-
Tax thereon (2,500 at 20%, 21,200 at 25%, 390 at 40%)--5,956.00
Tax at marginal rate on foreign dividend--40.00
Tax on foreign dividend (100 at 40%)--40.00
Less credit allowable--15.00
---25.00
Less UK tax deducted by paying agent--5.00
Further tax due--20.00
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