# Taxation (International and Other Provisions) Act 2010, Section 14: Rule 6: credit for underlying tax on dividend paid to 10% associate of payer


(1) This section applies for the purposes of section 12(1).
(2) Credit under section 9 for overseas tax on a dividend paid by a company (“P”) resident in the territory is allowed if conditions A and B are met.
(3) Condition A is that—
(a) the recipient of the dividend is a company resident in the United Kingdom, or
(b) the recipient is a company resident outside the United Kingdom but the dividend forms part of the profits of a permanent establishment of the recipient in the United Kingdom.
(4) Condition B is that the recipient—
(a) directly or indirectly controls, or
(b) is a subsidiary of a company which directly or indirectly controls,
at least 10% of the voting power in P.
(5) For the purposes of subsection (4), the recipient is a subsidiary of another company if the other company controls, directly or indirectly, at least 50% of the voting power in the recipient.

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Source: https://www.legislation.gov.uk/ukpga/2010/8/section/14 (the official version)
Page: https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-14
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.