Unilateral relief is also available under TIOPA 2010, s. 9 for the ‘underlying tax’ in respect of foreign dividends, i.e. the tax suffered on the profits of the foreign company out of which the dividends were paid.

(TIOPA 2010, s. 12(1) and s. 14 - 16)

The calculation of the amount of underlying tax for unilateral relief purposes follows the same rules as for relief under an agreement (see ¶172-400).

Any tax in respect of its profits paid by the overseas company under the laws of that territory is to be taken into account in considering whether any, and if so what, credit is in fact to be allowed under TIOPA 2010, s. 9 in respect of the dividend.

(TIOPA 2010, s. 12(2))

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