INTM164380 - UK residents with foreign income or gains: dividends

Unilateral relief - banks

ICTA88/S803

ICTA88/S803 limits the relief for underlying tax on certain dividends received by United Kingdom banks. These are dividends where the underlying tax is or includes foreign tax payable by reference to interest or dividends earned or received in the course of a company's business and S798 would apply to that company if it were resident in the UK.

Information about these provisions can be found at INTM168200. They are administered by the Underlying Tax Group at Nottingham, but Inspectors should ensure the UTG is aware of any such company amongst the overseas subsidiaries of a UK company.