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The expression 鈥減ortfolio investors鈥� describes the great majority of shareholders. They include individual persons, pension funds, companies and others who have invested money in shares issued by the UK company. The number of shares owned by each investor may range from single figures to several million shares. If a shareholder owns 10% or more of the total number of voting shares that have been issued by a UK company they are called a 鈥渄irect investor鈥�. See INTM343540.

Some Double Taxation Agreements (DTAs) contain provisions that allow a portfolio shareholder to claim payment of part of the tax credit. In these treaties the dividend article usually provides that the amount payable is equal to the tax credit minus 15% of the aggregate of the dividend and the tax credit.

The rate of tax credit that is attached to a UK dividend is one ninth of the dividend. The effect of this rate of tax credit is that there is no amount for a portfolio investor to claim (see F(No2)A1997/S30(10)).

Example

Dividend 拢1,000

Tax credit (one ninth) 拢111.11

Dividend plus tax credit 拢1,111.11

15% retained in the UK 拢166.66

Because the amount to be retained in the UK is greater than the original tax credit there is nothing to pay. 拢111.11 less 拢166.66 equals nothing.