United Kingdom Convention   2003 UNITED KINGDOM NOTES

No LGB 03/170  

With reference to Article 25 (Non-discrimination), the Contracting States agree that:

(a) in relation to paragraph 4 and subparagraph 6(c) of the Article, the reference to capital being owned or controlled " directly or indirectly " includes cases where the capital is held through a chain of companies or other entities; and

(b) nothing in the Article shall be construed as obliging a Contracting State to allow tax rebates and credits in relation to dividends received by a person who is a resident of the other Contracting State.

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