Commentary on Sections Overview Overview Section 14: Rule 6: credit for underlying tax on dividend paid to 10% associate of payer
57.This section specifies when, in principle, unilateral credit relief is allowed for underlying tax on a dividend paid to a substantial investor. It is based on section 790(5) to (6A) of ICTA.
58.The title of this section gives an indication of its contents. The title uses the expression “10% associate” by analogy with the use of that expression in section 64. Note, however, that the definition of “10% associate” in section 64(6) and (7) refers to control of at least 10% of the ordinary share capital, whereas the similar provision in subsections (4) and (5) does not.