Compaq Computer Corporation and Subsidiaries - Page 6




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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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