Related Commentary  

15(1)  This section applies for the purposes of section 12(1).

15(2)  Credit under section 9 for overseas tax on a dividend paid by a company (“P”) resident in the territory is allowed if each of conditions A to C is met.

15(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.

15(4)  Condition B is that the recipient–

(a)directly or indirectly controls, or

Need help? Get subscribed!

To subscribe to this content, simply call 0800 231 5199

We can create a package that’s catered to your individual needs.

Or book a demo to see this product in action.