Taxation (International and Other Provisions) Act 2010 Schedule 9 para 21

Conditions for relief for underlying tax paid by company lower in dividend-paying chain

Paragraph 21 of Schedule 9 provides a transitional simplification for underlying tax relief where dividends were paid between companies in a chain before 22 April 2009.

• This paragraph relates to the conditions for claiming relief for underlying tax paid by a company lower in a dividend-paying chain.
• The relevant provision is section 65(3)(a), which sets out conditions that must be met for such relief to apply.
• For dividends paid by a second company to a first company before 22 April 2009, the conditions are relaxed by removing one of the sub-requirements (sub-paragraph (ii)).
• For dividends paid on or after 22 April 2009, the full set of conditions in section 65(3)(a), including sub-paragraph (ii), must be satisfied.