Part 2Income tax, corporation tax and capital gains tax

Chapter 9International matters

Double taxation relief: general

85Dividends by reference to which a deduction is allowed: no underlying tax

1

In section 799 of ICTA (computation of underlying tax) after subsection (2) insert—

2A

No underlying tax shall be taken into account under subsection (1) above in the case of a dividend if, under the law of any territory outside the United Kingdom, a deduction is allowed to a resident of that territory in respect of an amount determined by reference to the dividend.

2

The amendment made by this section has effect in relation to dividends paid on or after 16th March 2005.