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amount of the shareholder credit to which an individual U.K.
resident shareholder would have been entitled.5
5 The relevant parts of Article 10 of the U.S.-U.K. Convention
provide:
Article 10
Dividends
(2) As long as an individual resident in the
United Kingdom is entitled under United Kingdom law to
a tax credit in respect of dividends paid by a
corporation which is resident in the United Kingdom,
paragraph (1) of this Article shall not apply. * * *
(a) In the case of dividends paid by a
corporation which is a resident of the United
Kingdom:
(i) to a United States
corporation which either alone or
together with one or more
associated corporations controls,
directly or indirectly, at least 10
per cent of the voting stock of the
corporation which is a resident of
the United Kingdom paying the
dividend, the United States
corporation shall be entitled to a
payment from the United Kingdom of
a tax credit equal to one-half of
the tax credit to which an
individual resident in the United
Kingdom would have been entitled
had he received the dividend,
subject to the deduction withheld
from such payment and according to
the laws of the United Kingdom of
an amount not exceeding 5 per cent
of the aggregate of the amount or
value of the dividend and the
amount of the tax credit paid to
such corporation;
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