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, Pt. 4, Ch. 3 or Ch. 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’.25 The liability to tax of a non-resident in relation to ‘disregarded income’ is restricted to the amounts deducted at source.26

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