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Posted Tue, 17 Sep 2024 06:44:47 GMT by Ioannis
I am a Greek tax resident and received an ordinary dividend from a UK resident limited company that distributed profits of past years. I have applied to the Greek tax authorities for a tax credit under Article XIV, paragraph 3 of the convention between UK and Greece for the avoidance of double taxation. The convention specifies that the tax credit in Greece shall take into account the corporation tax paid by the UK company in the UK for the corresponding to the dividend part of the company’s profits. The Greek tax authorities are requesting a certificate from HMRC that includes the following: a) The full details of the company that made the dividend distribution b) The amount of the dividend I have received c) The percentage of my participation in the share capital of the company d) The amount of corporation tax paid by the company for the corresponding to the dividend amount part of its profits e) Certification that the company is resident in the UK for the purposes of the application of the relevant Double Tax Convention I would be grateful if you could advise me how I could obtain such a certificate from HMRC to support my application in Greece for a tax credit under the UK-Greece Double Taxation Convention. Kind Regards Ioannis For convenience I copy below Article XIV, paragraph (3) of the UK-Greece Double taxation agreement “Subject to the provisions of the law of Greece regarding the allowance as a credit against Greek tax of tax payable in a territory outside Greece, United Kingdom tax payable, whether directly or by deduction, in respect of income from sources in the United Kingdom shall be allowed as a credit against any Greek tax payable in respect of that income. Where such income is an ordinary dividend paid by a company resident in the United Kingdom, the credit shall take into account, in addition to the United Kingdom tax appropriate to the dividend, the United Kingdom tax payable by the company on the corresponding part of its profits; and, where it is a dividend paid on participating preference shares and representing both a dividend at the fixed rate to which the shares are entitled and an additional participation in profits, the United Kingdom tax so payable shall likewise be taken into account in so far as the dividend exceeds that fixed rate: provided that the amount of the credit shall not exceed the amount of the Greek tax charged in respect of that income. “
Posted Wed, 25 Sep 2024 11:19:03 GMT by HMRC Admin 21 Response
Hi,
Unfortunately, we are unable to provide specific advice tailored to individual circumstances on this forum. This forum is for general queries only and is intended to help you self-serve. 
You are able to contact HMRC regarding general enquiries here: 
Income Tax: general enquiries
 Alternatively, you may wish to engage the services of a professional advisor/accountant to assist with your enquiry.
 Thank you.

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