Taxation (International and Other Provisions) Act 2010 section Schedule 9 para 14

Unilateral relief for underlying tax on dividends

Schedule 9, paragraph 14 restricts the availability of certain underlying tax credits on dividends by excluding events that occurred before 1 April 1972.

• This provision sets a historical cut-off date of 1 April 1972 for two specific types of underlying tax credit on dividends.
• Where a company's shareholding fell below the 10% threshold before 1 April 1972, the special credit for underlying tax on dividends paid to that sub-10% associate is not available.
• Where a share exchange took place before 1 April 1972, the special credit for underlying tax on dividends paid by the exchanged associate is not available.
• In both cases, the normal rules for underlying tax credit still apply — it is only the extended relief provisions that are blocked by the pre-1972 timing.