UK-Canada Double Taxation Treaty: Dividend Taxation for UK Companies

Hello, I am a UK resident and have a UK company that receives dividends from a Canadian company. My UK company holds 49% of shares of the Canadian company. The dividends will be subject to a 10% withholding tax in Canada, but I am not clear if the dividends should be subject to further tax in the UK or what affect the UK/CA double taxation treaty has in this scenario. Any advice / clarification would be very much appreciated. Thanks!

Hi.

Distributions are charged to Corporation Tax only if they are not exempt. Distributions received by companies are in most cases exempt from Corporation Tax under s.931A CTA 2009 whether

received from a UK or an overseas resident company. Please refer to guidance available on our website at:

Company Taxation Manual

and

International Manual

onwards.

Thank you.