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bigduckontax
bigduckontax, Accountant
Category: Tax
Satisfied Customers: 4198
Experience:  FCCA FCMA CGMA ACIS
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How does a UK company obtain relief for withholding tax levied

Customer Question

How does a UK company obtain relief for withholding tax levied on a dividend paid to it by a wholly owned subsidiary in Switzerland? Is the full amount of WHT paid deducted from the UK Corporation tax liability?
Submitted: 3 years ago.
Category: Tax
Expert:  bigduckontax replied 3 years ago.
Hello, I'm Keith and happy to help you with your question.


The double taxation treaty between the UK and Switzerland provides relief from UK taxation for tax paid in Switzerland. This relief would be claimed through the appropriate year CT600 tax return made by the company. In the event of the relief not appearing on the payment notice issued after the return is made HMRC's attention should be drawn to the matter by means of a letter so that the appropriate adjustment can be made.
Customer: replied 3 years ago.

Hi Keith, can I be clear on this. Is the WHT paid deducted from the UK CT payable (good) or the UK taxable income (bad!)?

Expert:  bigduckontax replied 3 years ago.
It is a credit against CT liability ie a deduction.
Customer: replied 3 years ago.

Perfect, thanks.

Expert:  bigduckontax replied 3 years ago.
Pleased to be of assistance.
bigduckontax and other Tax Specialists are ready to help you
Expert:  bigduckontax replied 3 years ago.

Thank you for your support.