Commentary on Sections Overview Overview Section 12: Rule 4: cases in which, and calculation of, credit allowed for tax on dividends
54.This section concerns unilateral credit relief for tax on dividends. It is based on section 790(5), (6) and (10) of ICTA.
55.Subsection (3) reflects the view that, in section 790(10) of ICTA, “if the company paying the dividend and the company receiving it were related to each other within the meaning of section 801(5)” means “if the company paying the dividend was related (within the meaning of section 801(5)) to the company receiving it”.