16 Rule 8: credit for underlying tax on dividend paid by exchanged associate
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

16  Rule 8: credit for underlying tax on dividend paid by exchanged associate

(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 each of conditions A to C is 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)

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