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The Double Taxation Relief (Taxes on Income) (United States of America Dividends) (Amendment) Regulations 1994
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- 1994 No. 1418
- Explanatory Note
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Explanatory Note
(This note is not part of the Regulations)
These Regulations amend the Double Taxation Relief (Taxes on Income) (U.S.A.) Regulations 1946 (S.R. & O. 1946/1331) (as amended) (“the principal Regulations”) which relate to the taxation of dividends from United States sources. The main changes made to the principal Regulations are twofold. First they revoke regulation 3 of the principal Regulations which required paying agents of United States dividends to give credit for United States withholding tax against United Kingdom income tax on the dividend. This regulation has been rendered unnecessary by the terms of a circular issued by the Inland Revenue which enables agents to give credit for United States and other foreign withholding taxes on dividends and interest.
Secondly the present Regulations substitute a definition of “chargeable person” for the definition of “paying agent” in regulation 2 of the principal Regulations, which more accurately describes the role of agents who obtain payment of United States dividends on behalf of those beneficially entitled to such dividends. The Regulations also make consequential alterations to the principal Regulations resulting from the substituted definition.
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