Commentary

D4.927 Effect of a UK company in a dividend chain

Corporate tax
Corporate tax | Commentary

D4.927 Effect of a UK company in a dividend chain

Corporate tax | Commentary

D4.927 Effect of a UK company in a dividend chain

FA 2009 introduced the exempt distribution regime which broadly provides that most dividends received by a UK company on or after 1 July 2009 (from the UK or overseas) will be exempt from corporation tax (see Division D5.1). The provisions discussed in this article apply to overseas dividends received on or after 1 July 2009 that are not exempt and all other overseas dividends received before 1 July 2009.

Where a UK company pays a dividend to an overseas company and the overseas company then pays the dividend to the UK, the dividend will be taxed in the hands of the parent UK company in the usual manner (as overseas dividend income) and the underlying rate on such dividends is calculated in the usual manner.

If the underlying tax rate is above the relevant UK corporation tax rate, the mixer cap would apply and the excess would not give rise to any eligible unrelieved foreign tax1 (see Example below). However, although the mixer cap applied to the UK dividend,

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