Distributing pre-2016 foreign dividends in 2022

An estate in administration received foreign dividends in 2015/16 from a country with a 15% DTT limit: £75 net, £25 foreign tax deducted The executors settled tax for 2015/16 with HMRC using the FTCR option: £75 net, £8.33 FTC used to cover the 10% UK tax, leaving £6.67 claimable FTC, and £10.00 excluded. The administration period completed in 2021-22 by which time the 7.5% dividend tax had replaced the 10% tax credit. The beneficiary, an IIP trust, received a payment of £75 with a reduced tax credit of 7.5%, which 'excluded' £2.25 of foreign tax paid. Hence R185(Estate) v1 Box 18 Dividend income (UK & Foreign): £75 net Box 18 Tax paid on dividends: £6.08 Box 24 Unclaimed FTCR element of foreign tax: £6.67 The IIP Trust needs to pay the dividend to its tenant in 2022-23, when the dividend tax is 8.75%. In this scenario, the beneficiary this breakdown: R185(Trust) v1: Box 7 Foreign income: Gross amount: 87.75 ( = £75.00 + £6.08 + £6.67 ) Foreign tax paid: £6.67 UK tax paid: £6.08 I can see an argument, however, that since the 10% tax paid in 2015/16 was a real payment of foreign tax rather than a 'notional' UK credit the £2.25 excluded from the R185(Estate) statement should have been added to the unclaimed FTCR. In this case, we'd have: R185(Estate) v2: Box 18 Dividend income (UK & Foreign): £75 net Box 18 Tax paid on dividends: £6.08 Box 24 Unclaimed FTCR element of foreign tax: £8.92 R185(Trust) v2: Box 7 Foreign income: Gross amount: 90.00 ( = £75.00 + £6.08 + £8.92 ) Foreign tax paid: £8.92 UK tax paid: £6.08 So my question is, which of these approaches is correct? (Or maybe they are both wrong?) TIA

Hi,
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Thank you.