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Posted Thu, 29 Feb 2024 14:47:41 GMT by Ann Q
Hi, If a residential property rented out is held under a Limited company (SPV), and the director of the company is non-uk resident. Does the director need to pay UK income tax if getting dividend from the SPV? Thanks.
Posted Fri, 01 Mar 2024 17:17:44 GMT by HMRC Admin 25
Hi 
It depends on what the double taxtion treaty says between the UK and whatever country this director lives in.
Thank you. 
Posted Fri, 01 Mar 2024 22:06:32 GMT by Ann Q
Thanks for the reply. From my understanding, dividend from UK companies paid to Non-uk resident can be treated as 'disregarded income' and therefore not liable to UK income tax. Can you confirm if this is correct? See link below: https://www.gov.uk/hmrc-internal-manuals/savings-and-investment-manual/saim1170 I also found a similar post before (link as below), and HMRC Admin 5 posted 3 months ago that "Individuals who are non resident in the UK are not taxable in the UK on UK interest or dividends received. " It does not mention anything about double taxation treaty. Can you explain a bit more about how double taxation treaty works here? https://community.hmrc.gov.uk/customerforums/pt/d0f9057b-3d87-ee11-a81c-000d3a86dfe6#:~:text=Individuals%20who%20are%20non%20resident,is%20known%20as%20disregarded%20income). Thank you.
Posted Tue, 05 Mar 2024 10:53:01 GMT by HMRC Admin 21
Hi Annie Qu,
Thank you for your question.
Please refer to our helpsheet HS300 Non-residents and investment income (2023) which provides more information about non-residents and investment income and how it is charged to tax.  Non-residents are not taxable on UK dividend income but this should still be declared if completing a Self Assessment tax return, for calculation purposes this will show as ‘Non-UK resident’s disregarded income’.
More information about double taxation and investment income can be found in SAIM1170 - Savings and investment income: non-residents.
Thank you.

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