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E1.416 Dividends from non-UK resident companies—general

In general, dividends of a non-UK resident company are charged to income tax as savings and investment income on the amount arising in the tax year. The charge is on the person receiving or entitled to the dividends¹. For HMRC's internal guidance, see SAIM5210. Guidance on dividend tax credits is at SAIM5102–SAIM5106. Other guidance on foreign dividends can be found at INTM164000–INTM164540.

This rule is modified in the case of shares acquired under a share incentive plan (see E1.417) and is subject to the general rules relating to assessment of foreign income² regarding (see Division E1.6):

1. Ìý

   •ÌýÌýÌýÌý assessment on the remittance basis

2. Ìý

   •ÌýÌýÌýÌý deductions for expenses of collection or annual payments

3. Ìý

   •ÌýÌýÌýÌý relief for unremittable income

In Beard³, the Upper Tribunal, when considering the correct UK tax treatment of distributions paid by a Jersey limited company derived from its share premium account, upheld the decision of the FTT and found that the distributions received by the taxpayer were