The Bolivian tax deducted from dividends at the agreement rate
of 15 per cent qualifies for credit as a direct tax. This reduced
rate does not apply if the dividends are effectively connected (see
INTM153110) with a business carried on through a permanent
establishment or fixed base which the recipient has in Bolivia.
A United Kingdom company controlling, directly or
indirectly, at least 10 per cent of the voting power of the
Bolivian company paying the dividend is entitled, under Article
23(1)(b), to credit for underlying tax (see INTM164010).
