Cuban company

We act for a UK company that provides services in the banking and financial services sector. The client owns 50% of the ordinary shares in a Cuban company that operates in the same sector in Cuba. The other 50% is owned by local individuals and corporates who are not connected to our client. Both of the companies have been making reasonably good profits.

We believe that there is no formal double taxation agreement between the two countries and would like advice on the UK tax implications of our client receiving a dividend directly from the Cuban company. Further are the tax rules in relation to controlled foreign companies likely to apply here?

We also wonder whether there are tax-efficient methods by which the UK company could receive dividends from the Cuban company either directly or by the dividend being routed via a company set up in another jurisdiction.

If...