Related Commentary  Related HMRC Manuals

14(1)  This section applies for the purposes of section 12(1).

14(2)  Credit under section 9 for overseas tax on a dividend paid by a company (“P”) resident in the territory is allowed if conditions A and B are met.

14(3)  Condition A is that–

(a)the recipient of the dividend is a company resident in the United Kingdom, or

(b)the recipient is a company resident outside the United Kingdom but the dividend forms part of the profits of a permanent establishment of the recipient in the United Kingdom.

14(4)  Condition B is that the recipient–

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