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Posted Mon, 25 Sep 2023 16:30:07 GMT by
Hello If a UK company owns investments in UK listed & foreign listed equity shares; and it receives dividends (net of withholding tax) on these investments:- are these dividends subject to further UK corporation tax ? or these dividends exempt from UK corporation tax and there is no further tax liability in the UK ? Pls clarify. Thank You
Posted Wed, 04 Oct 2023 14:30:51 GMT by HMRC Admin 20 Response
Hi kwality12,

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. You can find more information by going to ‘CTM15120’ and ‘INTM650000’.
If a company suffers overseas tax on dividends that are exempt from UK corporation tax, it will not pay tax again in the UK. However, some double-taxation agreements allow the rate of overseas tax applied to dividends to be reduced if those dividends are subject to tax in the UK. This is also known as the ‘treaty rate’. 
If a company wishes to claim a reduced rate of dividend withholding tax and the relevant double-taxation agreement requires that the dividends be subject to tax in the UK, the company will need to elect for the dividends to be taxable in the UK. You can find more information by going to www.gov.uk and searching ‘INTM655010’.

Thank you.
Posted Fri, 06 Sep 2024 11:58:47 GMT by silvnic
Hello, I am also interested in this topic. I've read through what you advised and also read the CTM15150 - Distributions: general: tax consequence. I have a question relating to the point that says "From 1 July 2009 - CTA09/S931A charges distributions from UK and non-UK resident companies to corporation tax, but then exempts these from charge in most cases." I understand that if my company receives a dividend from a UK or non-UK resident company the dividend received is exempt from corporation tax (in most cases). Is this correct? Does the same rule apply if the dividend is received from a distribution paying exchange-traded fund (ETF). The complexity here is that the ETF is made up of several companies or bonds within and outside the UK - I would assume that under CTA09/S931A it does not matter if the distribution is received by an ETF or not. Can you please correct me if I am wrong? Thank you.
Posted Wed, 18 Sep 2024 12:50:00 GMT by HMRC Admin 20 Response
Hi,
This can be a complex area and I would advise you to seek help from a financial/tax advisor that has experience in this area of taxation.
Thank you.

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