Section 13 | Rule 5: credit for tax charged directly on dividend

(1)This section applies for the purposes of section 12(1).

(2)Credit under section 9 for overseas tax on a dividend paid by a company (“P”) resident in the territory is allowed if—

(a)the overseas tax is charged directly on the dividend (whether by charge to tax, deduction of tax at source or otherwise), and

(b)neither P nor the recipient of the dividend would have borne any of that tax if the dividend had not been paid.