Non-resident directors
Treaties cap the source country's tax and give credit at home. With no UK dividend withholding tax, treaties mainly matter for your home country position.
Written and reviewed by Waqas Sagar Member of ICAEW, Fellow of ACCA, Fellow of AAT, a double graduate and entrepreneur at heart, helping startups grow and serving thousands of businesses nationwide with an excellent team. Published by LimitedCompany.Accountants, 12 London Road, Morden, London SM4 5BQ. Reviewed 12 September 2026 against 2026/27 UK rates and current Companies House and HMRC guidance.
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QuickBooks PartnerCertified ProAdvisor100+ yearsCombined team experienceFully insuredUp to £2m indemnityA treaty limits how much the source country can tax a dividend and requires the residence country to relieve double taxation by credit or exemption. Because the UK charges no withholding tax on dividends, the treaty mainly governs how your home country taxes them.
What treaties do and do not do
Claiming treaty benefits
A treaty limits how much the source country can tax a dividend and requires the residence country to relieve double taxation by credit or exemption. Because the UK charges no withholding tax on dividends, the treaty mainly governs how your home country taxes them.
Typical dividend articles allow the source state to tax at capped rates of 5% or 15%. The UK simply does not use that right for outbound dividends, so the cap is usually irrelevant and the practical question is what your home country charges and what credit it gives.
Treaties also cover director's fees, employment income, business profits and permanent establishments, plus the residence tie-breakers that matter when a UK company is managed abroad.
Home country claims usually need evidence of UK residence and UK tax paid. HMRC issues certificates of residence for the company on application, and dividend vouchers plus corporation tax computations support the underlying tax position.
Where no treaty exists, you rely on unilateral relief in your own country, which can be less generous. Check the treaty position before choosing between salary, fees and dividends.
Rates, thresholds and deadlines quoted here reflect the 2026/27 UK position and current Companies House and HMRC guidance. Check GOV.UK, or ask us, before relying on them for your own company.
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Frequently asked
No. Corporation tax on UK company profits is unaffected by the shareholder's residence.
Usually not for dividends. Relief is claimed in your country of residence.
HMRC publishes the UK's tax treaties by country on GOV.UK, with the dividend article numbered in each.
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No. This page explains general UK rules and common accounting treatment. Your facts, contracts and wider tax position must be reviewed before you rely on a conclusion.
Included approach
Check the current rules
Deadlines, thresholds and filing rules change. GOV.UK and Companies House publish the current statutory position; advice should then be applied to your company’s circumstances.
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