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Contents

Official guidance
International Manual

INTM343500 · DT applications and claims: Types of income: Dividends

  • INTM343510 · Background
  • INTM343520 · Portfolio investors
  • INTM343540 · Direct investors
  • INTM343550 · Direct investors - dividend stripping
  1. DT applications and claims: Types of income: Dividends: contents
  2. DT applications and claims: Types of income: Dividends: direct investors - dividend stripping

INTM343550 | DT applications and claims: Types of income: Dividends: direct investors - dividend stripping

From HM Revenue & Customs · International Manual

What dividend stripping is

Generally, no relief is available if the dividends can only have been paid out of profits earned or other income received by the UK company in a period ended more than 12 months before the date when the claimant acquired a holding of 10% or more of the class of shares on which the dividend is paid. This provision does not apply if the shares were acquired for genuine commercial reasons and not primarily for obtaining the benefit of relief under the Double Taxation Agreement (DTA).

When to make dividend stripping enquiries

The first time that the company claims payment of tax credits.

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