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GAYANE BABAYAN explains that few multinationals need to have fear of increased tax bills as a result of double taxation relief changes to be made by the proposed Finance Bill.
BEFORE DISCUSSING THE proposed changes that are to be made to TA 1988, s 801 , which only affects dividends received by a UK company after 2 December 2004, I will briefly consider the history of changes made to double tax relief on the dividends paid by related subsidiaries.
GAYANE BABAYAN explains that few multinationals need to have fear of increased tax bills as a result of double taxation relief changes to be made by the proposed Finance Bill.
BEFORE DISCUSSING THE proposed changes that are to be made to TA 1988 s 801 which only affects dividends received by a UK company after 2 December 2004 I will briefly consider the history of changes made to double tax relief on the dividends paid by related subsidiaries.
Dividends received on or after 31 March 2001
A UK company that receives a dividend on or after 31 March from an overseas company in which it owns more than 10% of the voting rights may claim a credit ( TA 1988 s 799 ) for tax paid on the profits of the overseas company and its subsidiaries. This tax is known as underlying tax.
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