Finance Act 1966

Section 31.

SCHEDULE 9 Company Dividends Paid to Non-Residents: Relevant Double Taxation Agreements.

1 Subject to the following provisions of this Schedule section 31 of this Act (in this Schedule called " the principal section ") shall apply to the double taxation agreements to which effect is given by the Orders in Council set out in the following Table

• The [S.R. & O. 1947/806.] Double Taxation Relief (Taxes on Income) (Australia) Order 1947.

• The [S.I. 1957/598.] Double Taxation Relief (Taxes on Income) (Austria) Order 1957.

• The [S.I. 1950/1195.] Double Taxation Relief (Taxes on Income) (Denmark) Order 1950, including that Order as extended by the [S.I. 1961/579.] Double Taxation Relief (Taxes on Income) (Faroe Islands) Order 1961.

• The [S.I. 1955/1203.] Double Taxation Relief (Taxes on Income) (Federal Republic of Germany) Order 1955.

• Any Order in Council made in the form of the draft Double Taxation Relief (Taxes on Income) (Federal Republic of Germany) Order in Council laid before the Commons House of Parliament on 11th March 1965.

• The [S.I. 1953/191.] Double Taxation Relief (Taxes on Income) (Finland) Order 1953.

• The [S.I. 1951/1388.] Double Taxation Relief (Taxes on Income) (France) Order 1951.

• The [S.I. 1963/887.] Double Taxation Relief (Taxes on Income) (Japan) Order 1963.

• The [S.I. 1951/1798.] Double Taxation Relief (Taxes on Income) (Norway) Order 1951.

• The [S.I. 1961/2467.] Double Taxation Relief (Taxes on Income) (Pakistan) Order 1961.

• The [S.I. 1962/2352.] Double Taxation Relief (Taxes on Income) (South Africa) Order 1962, including that Order as extended by the [S.I. 1962/2788.] Double Taxation Relief (Taxes on Income) (South West Africa) Order 1962.

• The [S.I. 1961/577.] Double Taxation Relief (Taxes on Income) (Sweden) Order 1961.

Australia.

2 In applying Article VI(3) in the [S.R. & O. 1947/806.] Double Taxation Relief (Taxes on Income) (Australia) Order 1947 (under which the limiting rate of tax is a fraction of the full rate of the Australian tax) to a dividend paid (by a company resident in the United Kingdom) in any year of assessment it shall be assumed that in the converse case described in subsection (2) of the principal section the dividend (assumed paid by a company resident in Australia) is paid in the Australian year of tax beginning in the same calendar year as that in which the said income tax year of assessment begins.

Federal Republic of Germany.

3 In applying Article VI in any Order in Council made in the form of the draft Double Taxation Relief (Taxes on Income) (Federal Republic of Germany) Order in Council laid before the Commons House of Parliament on 11th March 1965 paragraph (2) of that Article (different rates of German tax on distributed and undistributed profits) shall be disregarded.

France.

4 (1) Article VII of the [S.I. 1951/1388.] Double Taxation Relief (Taxes on Income) (France) Order 1951 as applied by the principal section shall be read as having the result in sub-paragraph (2) below.

(2) The rate at which income tax under Schedule F is chargeable on a dividend paid to a company which is a resident of France, and which has owned for a year capital representing at least 50 per cent. of the capital of the company paying the dividend, shall not exceed 10 per cent

Pakistan.

5 (1) Article VI of the [S.I. 1961/2467.] Double Taxation Relief (Taxes on Income) (Pakistan) Order 1961 as applied by the principal section shall be read as having the result in sub-paragraph (2) below.

(2) The rate at which income tax under Schedule F is chargeable on a dividend paid to a public company which is a resident of Pakistan and which owns more than 50 per cent. of the voting shares of the company paying the dividend shall not exceed 10 per cent.