Amichai Pery
Joined: 7/7/2024
-
Foreign dividends distributed to a UK resident not domiciled
My friend received some dividends from abroad. According to the tax treaty between the UK and the other country, the withholding tax rate is limited to 15%, if the dividends are “subject to tax” in the UK. According to INTM162090, the whole dividend income is considered “subject to tax”, even though “little or no tax” is paid in the UK on the year of distribution (assuming the dividends were not remitted in the UK). We would like to verify the above. We would like to ask if there is a difference between the years that no UK tax was paid, during the first 7 years of UK residency, and the following years, where 30,000 £ annual remittance basis tax was paid.