INTM164370 - UK residents with foreign income or gains: dividends

Unilateral relief - underlying tax - chains of companies

ICTA88/S801

Section 801 extends Section 790(6) to chains of companies. Credit relief is available to a United Kingdom company receiving a dividend from a foreign company that it controls directly or indirectly, or is a subsidiary of a company which controls directly or indirectly, 10 per cent of the voting power in the shares of the foreign company paying the dividend and that company in turn controls directly or indirectly, or is a subsidiary company of a company which controls, 10 per cent or more of the voting power in the third company and so on. Relief is given for the underlying tax for third and successive companies. Detailed instructions on Section 801 are given in INTM167380 onwards.