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Taxation (International and Other Provisions) Act 2010

Section 65: Relief for underlying tax paid by company lower in dividend-paying chain

171.This section provides for tax payable by the company paying the dividend to be treated as underlying tax paid by the dividend’s recipient. It is based on section 801(1), (2), (2A), (3), (4) and (5A) of ICTA and paragraphs 8(5) and 11(3) of Schedule 30 to FA 2000.

172.Subsections (2) and (3) set the conditions for the section to apply.

173.Subsection (4) is the main operative provision. Subsection (4)(b) enables the section to be applied repeatedly and thus deals with dividend-paying chains of companies comprising more than three companies.

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