C1Part 2Double taxation relief
Annotations:
Modifications etc. (not altering text)
CHAPTER 1Double taxation arrangements and unilateral relief arrangements
Unilateral relief arrangements
13Rule 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.
Pt. 2 modified by 1988 c. 1, Sch. 19ABA paras. 26-28 (as inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 34(3) (with Sch. 9 paras. 1-9, 22))