Taxation (International and Other Provisions) Act 2010 section 63

Non-UK company dividend paid to 10% investor: relief for UK and other tax

Section 63 allows certain taxes paid by an overseas company on its profits to be treated as underlying tax for the purpose of giving credit relief when that company pays a dividend to an investor holding at least 10% of the voting power.

• The recipient company (or its parent) must control at least 10% of the voting power in the overseas company paying the dividend.
• The recipient must either be UK-resident, or be non-UK-resident with the dividend forming part of the profits of its UK permanent establishment.
• Any UK income tax or corporation tax paid by the overseas company on its profits can be counted as if it were tax paid in the overseas company's country of residence.
• Tax paid by the overseas company in any third country (outside both the UK and its own country of residence) is also brought into account in the same way.