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Closed Tax advice (dividend to non UK-resident shareholders)

Monika

posted on Wednesday 29 April 2020

expired on Friday 15 May 2020

B, Birmingham, West Midlands
A UK ltd company that has only two shareholders, both of Polish nationality and living in Poland, would like to pay out dividends to those shareholders. They have only been in the UK a few times for travel purposes over the years. The company's business is online sales (women's clothing etc). We seek advice on proper tax treatment in the UK (in particular - what tax and at what rate should the shareholders pay in the UK). The same shareholders have been recently paying out dividends in a company incorporated in Germany, and they had to pay 15% tax in Germany and 4% tax in Poland so that the total would be 19%... Advisers on the Polish side are of opinion that apart from tax in Poland (at 19% tax rate), dividend is also taxed in the United Kingdom. And that according to the Poland-UK Double Taxation Convention the tax rate deducted in the UK cannot exceed 10% of the dividend amount (gross) and that 0% rate cannot be used.

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