Dividends and other distributions from UK-resident companies are generally not liable to income tax in the hands of non-residents as a matter of domestic law. The legislative route to this simple treatment is convoluted: dividends and other distributions from the UK companies are within the charge to income tax under ITTOIA 2005, Part 4, Chapter 3 or Chapter 5. There is no provision for the deduction of tax at source on such amounts; dividends and other distributions from UK companies are ‘disregarded income’.28 The liability to tax of a non-resident in relation to ‘disregarded income’ is restricted to the amounts deducted at source.29

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.