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A direct investor, as defined in INTM164010 (g), is a company which controls directly or indirectly not less than a certain percentage (see INTM164360) of the voting power of the company paying the dividend. It is entitled to tax credit relief for the direct tax charged on a dividend in addition to underlying tax paid on the profits from which the dividend was paid

In addition to tax credit relief for the direct tax on a dividend, where the UK resident shareholder is a company controlling directly or indirectly not less than 10% of the voting power in the foreign company paying the dividend, it is entitled to relief for the underlying tax attributable to the dividend (see INTM164440). »Ê¹ÚÌåÓýapp percentage required by the relevant treaty is given in the Credit Article. If this is a higher percentage the UK will allow companies controlling at least 10% to claim underlying relief unilaterally.