A British investor living in France may see a French tax notice refuse a credit claimed against UK dividends. The refusal does not, by itself, prove that France has taxed the same income unlawfully. The first question is what the payment really was: an ordinary dividend from a UK company, a property income distribution (PID) from a UK Real Estate Investment Trust, or a payment that the broker has labelled incorrectly. The second question is whether any UK tax was actually and definitively borne. A French crédit d’impôt, meaning a tax credit used to relieve double taxation, is not the same as the French tax charged on the dividend and is not an automatic refund of a historic UK dividend credit. After Brexit, the current France–UK convention, the French General Tax Code, the current form 2047 and HM Revenue & Customs evidence still have to be read together. This article explains how to diagnose a refusal, rebuild the calculation, separate an HMRC repayment from French treaty relief and file a timely challenge. It is aimed at an individual resident in France; a company, trust, pension wrapper or estate requires a separate analysis.

I. UK dividends in France after Brexit: which tax credit can legally exist?

A. Why does France tax the dividend and why can a French credit still be refused?

The phrase “UK dividend” covers several different legal situations. A shareholder may hold shares in a normal UK trading company, a UK Real Estate Investment Trust (REIT), an investment trust, an exchange-traded fund or an account containing several instruments. The payment may be described as a dividend on a bank statement even though the issuer’s tax voucher identifies a property income distribution, interest, a return of capital or a different form of distribution. The analysis begins with the issuer’s voucher and the payment record, not with the label used by a portfolio application.

If you are resident in France, the domestic starting point is worldwide taxation. Article 4 A of the French General Tax Code states: “Les personnes qui ont en France leur domicile fiscal sont passibles de l’impôt sur le revenu en raison de l’ensemble de leurs revenus.” In English, a person whose domicile fiscal—French tax residence—is in France is assessed on the whole of their income. Article 4 A also distinguishes a person whose tax domicile is outside France, who is generally assessed on French-source income. That domestic rule does not answer the treaty question, but it explains why an offshore brokerage account does not make a dividend disappear from the French return.

Residence itself must be checked for the relevant year. Article 4 B of the French General Tax Code uses factors such as the home or main stay, professional activity and centre of economic interests, subject to the applicable treaty. A British citizen who moved to France during the year cannot automatically describe every payment in that calendar year as French-resident income without examining the move date, the household, the work position and any competing UK residence status. The France–UK convention may allocate residence between the two states by its tie-breaker rules. A residence certificate supports a claim but does not replace the factual analysis.

France then classifies foreign distributions under its own income-tax rules. Article 120 of the French General Tax Code includes foreign-source distributions in the category of movable capital income. The domestic French charge on that income is not the same thing as UK withholding. Depending on the taxpayer’s situation and the income’s legal category, French tax may include the prélèvement forfaitaire unique (PFU), meaning the French flat-tax framework for qualifying investment income, and social levies. A line showing French tax on a dividend is therefore not proof that an equivalent amount of UK tax was paid.

Article 117 quater of the French General Tax Code illustrates the distinction. For an individual who is fiscally domiciled in France and receives the relevant distributed income, it provides for a French levy at 12.8 per cent and says that the income is taken at its gross amount. Its wording begins: “Les personnes physiques fiscalement domiciliées en France au sens de l’article 4 B qui bénéficient de revenus distribués…” This is a French domestic mechanism. It is not the treaty article that turns UK tax into a French credit, and it is not a direction to claim a notional UK deduction.

There are three different amounts that are often called a “credit” in correspondence:

• French income tax or a French levy calculated on the gross dividend;
• a foreign-tax credit allowed under the France–UK convention for UK tax actually and definitively borne, within the treaty and French limits; and
• a repayment of excess UK withholding obtained from HMRC because the UK deduction exceeded the rate or relief available to the claimant.

Only the second is the French treaty credit. The third is a UK repayment. They may interact, because a UK repayment reduces the foreign tax ultimately borne, but they are not interchangeable. If HMRC returns part of the amount deducted, France should not continue to treat that returned amount as tax that remained paid in the United Kingdom. Conversely, a refusal by HMRC does not automatically create a French credit. The final question remains whether the tax was a qualifying UK tax under the convention and whether the French form and evidence support it.

The old UK dividend imputation credit creates a particularly common trap. The French tax administration’s BOFiP commentary on the France–UK convention records that the 2008 convention ended the former mechanism under which French residents could look for a UK imputation credit attached to dividends. It explains that French residents no longer benefit from the former UK credit for distributions covered by the post-2009 treaty position. A broker’s old explanatory note, an internet forum or a historic calculation may therefore be describing a system that no longer applies. Do not present a former imputation credit as UK tax paid on your current dividend.

Ordinary UK company dividends must also be separated from REIT PIDs. HMRC describes a PID in its current Savings and Investment Manual as generally taxable as profits of a UK property business. HMRC’s short description is: “The PID is generally taxable as profits of a UK property business.” The voucher normally shows a gross PID, UK income tax deducted and the net cash. A normal dividend from a company that also operates a REIT may have a different treatment from a PID made out of the property rental business. The refusal of a credit for an ordinary dividend should not be repaired by using the UK-REIT claim form, and a PID should not be hidden among ordinary dividends.

For an ordinary UK dividend, ask why any UK tax is shown at all. The entry may be a PID deduction, a broker fee, a currency conversion adjustment, a tax entry from another country, or a correction made by a custodian. UK tax on the shareholder’s overall dividend income and tax deducted at source are also different concepts. Obtain the company’s dividend voucher and the broker’s full transaction statement. The evidence should identify the issuer, the gross payment, the date, the currency, every deduction and the person entitled to the income.

The account wrapper matters as well. A dividend paid into a UK Individual Savings Account (ISA), Self-Invested Personal Pension (SIPP), personal pension, trust or company account is not automatically treated like a dividend paid directly to an individual resident in France. The wrapper may alter the beneficial owner, reporting route or treaty analysis. A French resident who receives a personal distribution after an entity-level payment must trace the legal payment chain. A tax credit cannot be calculated safely from the amount eventually transferred to a French current account.

The practical diagnostic is simple: identify the issuer and legal character, identify the recipient and beneficial owner, identify the country and amount of tax actually withheld, and then identify the legal provision said to create the credit. If a refusal letter merely says “foreign tax credit not allowed”, request the precise reason. The remedy will be different if the office has rejected a missing form, a wrong income category, a claim for a non-existent UK tax, a residence problem or a treaty ceiling.

B. What does the current France–UK treaty allow, and how should the calculation be rebuilt?

The governing instrument is the 2008 France–UK double taxation convention. The official GOV.UK publication confirms the convention’s entry into force and effective dates. The treaty is also published in France by Decree no. 2010-20 in the Journal officiel on Légifrance. Brexit did not turn a UK-source dividend into a treaty-free payment. The correct convention still has to be applied to the taxpayer’s residence, the issuer, the income and the tax actually imposed.

Article 11 deals with dividends. It provides that “Dividends arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.” In practical terms, France may tax a French-resident individual on the dividend. The United Kingdom may also have a source-state taxing right in the situations covered by the article, but the treaty contains limits and conditions. The official synthesised treaty text and HMRC’s France treaty table must be read for the exact category. The portfolio rate and the special treatment of a REIT property income distribution should not be merged into one universal percentage.

Article 24 sets out the relief method. The operative question is not whether the payment was described as “foreign”, but whether UK tax was effectively and definitively borne and whether the credit is available under the convention. Relief is normally capped by the French tax attributable to the relevant income and by any treaty limit. A source-state deduction that was excessive may first be claimed back from HMRC. A UK tax that was refunded cannot then be counted again as tax definitively borne in France.

Use a three-line calculation for every payment. Line one is the gross dividend stated on the voucher. Line two is UK tax actually withheld and ultimately retained after any HMRC repayment. Line three is the maximum French credit allowed by the applicable treaty method and the French tax attributable to that income. The credit is the lower permitted amount, not necessarily the amount shown on the broker statement. If there is no UK tax on an ordinary dividend, the treaty credit for UK tax is normally nil even though France still taxes the dividend.

Consider a normal UK company dividend of £10,000 paid to a French resident. If the company paid £10,000 and the broker credited £10,000 without UK tax, there is no UK tax to credit merely because the dividend is UK-source. The dividend must still be converted into euros using the method applicable to the French return and declared under the correct foreign-income category. The French tax assessed on that income is French tax, not a foreign credit. A request asking France to “refund 15 per cent of the dividend” would be aimed at the wrong legal mechanism.

Now consider a statement showing a gross payment of £10,000 and £2,000 described as UK income tax. First establish whether it is a PID or another payment that can lawfully bear the deduction. If a treaty cap of 15 per cent applies to the payment and all conditions are satisfied, £1,500 is the initial treaty-rate comparison and £500 may be the starting amount of an HMRC repayment claim. That is not an automatic result: the correct form, the payment date, treaty residence, beneficial ownership, any REIT exception and the current HMRC evidence requirements still control. If HMRC repays £500, the final UK tax retained is £1,500, not £2,000.

The French credit calculation must then use the final foreign tax position. It may be lower than £1,500 if the French tax attributable to the income is lower, if the treaty method imposes a different ceiling, if the payment was misclassified, or if part of the UK deduction was not a tax that qualifies for relief. An amount returned by HMRC is not a second dividend and should not be added to the gross income. It is a repayment of an excessive deduction. Keep the HMRC decision with the French calculation so that the sequence is visible.

The French tax administration’s guidance on foreign-source income directs taxpayers to the treaty to determine whether income is taxable, exempt or eligible for double-tax relief. The current form 2047 page says that a person domiciled in France who received income outside metropolitan France or the overseas departments must file the foreign-income declaration with the main return. The 2026 notice instructs taxpayers to report foreign income on form 2047 and carry the figures to the relevant main return. It also explains the foreign-tax credit calculation and the gross-income approach for securities income.

The notice’s wording on the credit is useful evidence: “Le crédit d’impôt indiqué en 8VL est égal à l’impôt effectivement supporté à l’étranger”. The rest of the instructions and the applicable treaty limits matter, but this sentence shows why a notional UK credit, an old imputation credit or a tax that was later refunded cannot simply be inserted into the French credit box. The current notice also contains a country table for the United Kingdom. Treat that table as a calculation aid, not as permission to claim a credit when no qualifying UK tax was actually borne or when the payment falls within a different treaty category.

Article 200 A of the French General Tax Code provides the domestic framework for the treatment of distributions and the treaty-credit mechanism. Its application must be read with the convention and the relevant category rules. Article 170 of the same Code supplies the declaration framework and requires foreign income to be dealt with in the detailed annual return. These provisions explain why entering the net cash received, without the gross amount and the foreign tax history, can produce a refusal even where the taxpayer has suffered a genuine deduction.

The refusal should therefore be mapped to one of five questions:

1. Was the income an ordinary dividend, a PID or another form of distribution?
2. Was the claimant French-resident under domestic law and the treaty for the payment concerned?
3. Was the claimant the beneficial owner and was the payment received in the claimed capacity?
4. Was UK tax actually, legally and definitively borne after any repayment or adjustment?
5. Was the gross income and the credit entered on the correct French forms within the applicable time limit?

That map prevents a common error: challenging a lawful refusal as if it were a simple arithmetic mistake. If the claimed amount is the former UK imputation credit, the correct response is to withdraw or reformulate the claim. If the office ignored a current HMRC repayment decision or treated a gross PID as net cash, the evidence may support a correction. If the dispute concerns residence, the file needs facts and treaty analysis rather than a screenshot of the dividend payment.

II. How to correct a refused French credit and protect the appeal?

A. Which documents and filing sequence should a British resident use?

Build the file before sending a challenge. Make a separate schedule for each issuer and payment date. Record the legal name of the company, the ISIN or share identifier, the type of distribution shown on the voucher, the gross amount, currency, exchange rate used in the French return, UK tax deducted, net payment, any repayment claim and the final amount retained. Add the account holder, the account wrapper and the date on which the payment was available. A table that follows the money is more persuasive than a portfolio export showing only annual net cash.

For an ordinary dividend, obtain the issuer’s dividend voucher or corporate action notice and a broker statement showing that no UK tax was withheld, or explaining the deduction that appears. If the broker describes the payment as “tax”, ask which authority received it and under what legal category. A commission, stamp duty, fund expense or currency adjustment is not automatically a creditable foreign income tax. If the statement is corrected, retain both versions and a short explanation from the broker.

For a PID, do not use the ordinary dividend route. HMRC’s UK-REIT DT-Individual form and notes are designed for the relevant UK REIT payment. The current notes require the payment to have occurred before a tax repayment claim is made. They also require the claimant to complete the residence and entitlement information in the manner specified by HMRC. A PID needs its own gross-to-net schedule. This article’s narrow issue is the refused French credit; a UK REIT repayment may be a preceding or parallel step, not a replacement for the French declaration.

Check the legal owner. If the shares are held in a joint account, use the ownership evidence and the tax allocation rather than assuming an equal split. If a nominee holds the shares, identify the person entitled to the income and obtain the custody statement. If a company, trust, estate or pension scheme received the distribution, stop before filing an individual claim. The individual’s eventual receipt of money does not, on its own, make the individual the treaty claimant for the original distribution.

Check residence for the payment year and, if needed, for each part of a split-year move. Keep the French tax residence certificate, the move chronology, French and UK address evidence, the household position, work records and any UK certificate used by HMRC. A certificate is particularly important when claiming a UK repayment, but the French administration may still ask why the treaty’s residence article points to France. A person who spent time in both countries should not rely on nationality as a substitute for residence.

Complete form 2047 before transferring the relevant amount to the main French income-tax return. The French form is not a general “foreign dividend” box: the payment must be placed in the correct category and the gross amount must be reconciled to the tax voucher. Follow the current year’s instructions and conversion rules. Where a foreign tax credit is claimed, record the tax actually borne after the UK process is known. If the UK claim is still pending when the French return is filed, retain a provisional schedule and correct the French position when HMRC issues its decision.

The intermediary’s reporting may help but does not decide the treaty issue. Article 242 ter of the French General Tax Code contains information duties for payers and intermediaries, including the beneficiary and relevant income amounts. A broker tax certificate may therefore be useful evidence. It can still be wrong or incomplete for a cross-border classification. Compare the certificate, corporate action, account statement and French forms. Where they disagree, ask for a written correction before relying on the most favourable figure.

File the UK and French documents in a sequence that makes the tax history intelligible:

1. preserve the original voucher and broker statement;
2. classify the payment as ordinary dividend, PID or another distribution;
3. confirm the residence and beneficial-owner position;
4. claim any excessive UK withholding through the current HMRC route, after the payment date;
5. declare the gross income in France using form 2047 and the relevant main return;
6. calculate the French treaty credit on the UK tax that remains definitively borne;
7. attach the HMRC result when it arrives and correct any provisional French calculation; and
8. retain submission receipts, correspondence and the final assessment.

The order does not mean that a French return must always wait for HMRC. A return deadline can expire before a UK repayment is decided. In that situation, declare the income correctly, keep a conservative documented credit calculation and update it when the UK result is available. If the credit is refused later, the file should show that the taxpayer did not conceal the income or claim tax that had already been refunded. A secure message to the French tax office can explain that the UK claim is pending and identify the expected supporting document.

Use the current form and instructions, not a saved PDF from a previous tax year. Rates, addresses, thresholds and online procedures can change. The UK treaty table itself warns that a treaty rate is a maximum and does not necessarily override a lower domestic charge. The French 2026 notice also changes the way certain amounts are displayed compared with earlier forms. Record the form year and the date downloaded in the evidence schedule. That small step prevents a refusal caused by a form from an obsolete tax year.

A British resident who holds an investment account in the UK should also check separate French reporting obligations for foreign accounts. The dividend line and the account declaration are different questions. An account can need reporting even where it produced no taxable dividend, and a dividend can be taxable even where the account has been declared. Do not use the fact that a bank reported the payment to France as a reason to omit the account information or to assume that the tax office has already accepted the credit calculation.

When sending documents to the service des impôts des particuliers (SIP), meaning the French individual tax office, use a short index. Put the tax year, notice number, issuer, payment date, gross income and credit claimed on the first page. Then attach the voucher, the broker statement, the treaty residence evidence, the UK repayment result and the calculation. Explain each French term the first time it appears in an English-language letter: revenus encaissés à l’étranger means income received abroad; crédit d’impôt means a foreign-tax credit; réclamation contentieuse means a formal claim disputing an assessment. Clear labels reduce the risk that an officer treats a UK repayment as a second income receipt.

Keep a second calculation for the alternative outcome. Show the position if HMRC repays the UK deduction and the position if HMRC rejects the repayment. This is not a request for double relief. It is a way to show the French office how the foreign tax changes. The final claim should be the lower legally supported amount. If the figures cannot be reconciled because the broker has not supplied a voucher, say so and request the document rather than filling the gap with an assumed rate.

B. What are the remedies when HMRC or the French tax office refuses?

Read the refusal’s legal and factual reason before replying. A French refusal may concern the absence of proof that UK tax was paid, the use of a wrong line on form 2047, a net rather than gross declaration, the application of an old imputation credit, a mismatch between the claimant and beneficial owner, or the operation of the treaty ceiling. HMRC may reject a parallel repayment because the payment was not a PID, the claim was made before payment, the residence evidence was incomplete, the ten per cent or another REIT condition applied, or the voucher did not support the stated tax.

For HMRC, start with an evidence-based response or review under the route stated in its decision. Identify the exact distribution, payment date and voucher. State whether you are claiming a treaty repayment, an allowance-based outcome or a correction to the payment classification. Attach the current residence certification, voucher, broker statement and calculation. If the claim concerns a normal dividend, do not describe it as a PID. If the claim concerns a PID, do not send an ordinary-dividend schedule. Ask HMRC to explain any difference between its calculation and the current treaty table.

For France, begin with the secure messaging service or the tax office identified on the assessment. Ask whether the administration needs a corrected return, supporting documents or a formal claim against an issued assessment. Do not send a general complaint about Brexit. Set out the legal chain: the payment was made by a UK issuer; the claimant was resident in France under the relevant treaty analysis; the gross income was declared; the UK tax was or was not actually withheld; any UK repayment was or was not obtained; and the French credit requested is limited to the tax definitively borne and the convention’s ceiling.

If the tax notice has already been issued, the formal route is a réclamation contentieuse. Article L. 190 of the French Tax Procedures Code defines the purpose of claims, including “la réparation d’erreurs commises dans l’assiette ou le calcul des impositions”. The words matter: the claim should identify an error in the assessment or the application of a statutory or treaty right. A request that simply asks for an ex gratia refund, without showing the error and the legal basis, is weaker.

Protect the deadline as soon as the notice or refusal arrives. Article R* 196-1 of the French Tax Procedures Code sets a general framework for the time allowed for certain claims, often referring to 31 December of the second year following the relevant assessment, payment or event. The precise starting point and any special rule depend on the type of tax and dispute. A treaty credit attached to an income-tax assessment may not follow the same rule as a withholding or repayment claim. Record the date of the notice, the date received, the proposed deadline and the legal basis used. If documents are still missing, a protective claim can preserve the issue while the evidence is completed where the procedure allows it.

French case law reinforces the need to start with the domestic tax base and then apply the treaty carefully. In Conseil d’État, 31 May 2022, no. 461519, the court considered the relationship between domestic law and a tax convention and held, in the facts before it, that a convention cannot by itself be the sole legal basis for a tax assessment. For a British dividend claimant, the practical lesson is limited but important: identify the French domestic provision that taxes the income, then show the treaty provision that requires relief. A convention is not a free-standing refund formula.

In Conseil d’État, 24 April 2019, no. 399952, the court examined the ceiling for a foreign-tax credit in a corporate setting and the relationship between the amount of foreign tax and the treaty relief. This was not an individual ruling on a UK dividend, so it must not be copied mechanically. It is nevertheless useful when the administration asks why the claimed credit exceeds the treaty or French-tax limit. The calculation must be anchored in the applicable convention and the tax actually borne, not just in the amount withheld by an intermediary.

In Conseil d’État, 9 October 2024, no. 472947, the court dealt with UK dividends and the interaction between treaty relief and the French tax base in a corporate dispute involving earlier treaty wording. Again, this is not authority for copying a corporate calculation into an individual’s form 2047. It is a warning to check the convention’s date, the taxpayer’s legal status and the gross income included in the French base. A decision under an earlier version of the France–UK treaty cannot revive the former UK imputation credit.

These decisions also explain why a refusal cannot be overturned by quoting only the 15 per cent figure. The number may be a treaty maximum for a particular payment, but it does not prove that the payment is within that article, that the claimant is entitled to it, or that the UK tax was definitively borne. Conversely, an office cannot reject a properly documented claim by pointing only to the word “foreign” in a tax form. The written response should address classification, residence, ownership, tax payment and the ceiling separately.

Correct the French return if the problem is a factual entry. If the gross dividend was entered as net cash, provide the voucher and a revised calculation. If a UK repayment arrived after filing, show the original UK deduction, the repayment and the final tax retained. If no UK tax was ever paid on an ordinary dividend, remove the foreign credit but keep the dividend declaration. If the refusal concerns a tax that was paid but not recognised, attach proof that the amount was remitted to HMRC and was not subsequently refunded.

Correct the classification if the problem is an ordinary dividend versus PID. For an ordinary dividend, use the French foreign-income route and explain the actual UK withholding, if any. For a PID, review the current UK-REIT form, the treaty category and the payment voucher. A REIT may issue both ordinary dividends and PIDs in the same year. One line can qualify for a repayment route while the other does not. The French return must preserve that distinction rather than applying a single rate to the entire annual cash total.

Escalate the residence issue only with a factual file. Include the dates the home was available in each country, the household’s location, work arrangements, bank and medical administration where relevant, and the centre of economic interests. Explain the treaty tie-breaker in plain terms. A British passport, a French residence card or a UK mailing address is relevant evidence but not conclusive by itself. The tax office needs to see why France was the treaty residence for the income concerned and why the UK tax, if any, falls within the relief article.

After domestic exchanges, a genuine unresolved treaty dispute may be considered under the mutual agreement procedure (MAP). Article 26 of the France–UK convention allows a person to present a case to the competent authority where taxation is not in accordance with the convention, subject to the treaty’s conditions and time limits. The official treaty text is the source for the current wording. MAP is not a substitute for a missing voucher, a late ordinary filing or an untested HMRC repayment claim. It is a last-stage treaty process for a documented double-taxation problem that domestic contacts have not resolved.

Use the following refusal checklist before signing the claim:

1. Obtain the written refusal and identify the exact year, payment and legal reason.
2. Confirm whether the payment was an ordinary dividend, PID or another distribution.
3. Reconcile gross amount, tax deducted and net cash to the issuer and broker records.
4. Prove French treaty residence and beneficial ownership for the relevant payment.
5. Remove any former imputation credit or UK tax that was never actually paid.
6. Recalculate after any HMRC repayment, using only foreign tax finally borne.
7. Check the current 2047 instructions, the assessment date and the claim deadline.
8. File the correction or formal claim with an indexed evidence bundle and submission proof.
9. Consider MAP only if a real treaty conflict remains after the domestic record is complete.

For a British reader, the safest correspondence can remain in English while preserving the original French terms and legal links. Do not translate a tax category so freely that its meaning changes. “Dividend” may be dividende, while a PID is identified by its UK tax character and can be treated differently. “Tax credit” is crédit d’impôt; “repayment” is a refund of tax deducted; “assessment” is an avis d’impôt or other French tax assessment; and a formal challenge is a réclamation contentieuse. Put the French term in brackets beside the English description, then use it consistently.

Do not close the file when the French office sends a revised notice. Check that the gross dividend, the French tax, the foreign credit and any UK repayment now correspond. Review the next broker certificate and the next form 2047. A corrected voucher can affect more than one tax year if the issuer has restated a payment. If the distribution was held through an ISA, SIPP, trust or company, recheck the owner and the reporting route before reusing the previous schedule.

A refusal can be lawful and still reveal a fixable filing error. It can also conceal a real failure to apply the convention. The decisive step is to show the complete chain in documents: legal character, gross income, UK deduction, UK repayment, French declaration, treaty limit and final credit. That chain gives the tax office a concrete calculation to accept or reject and gives the taxpayer a clear basis for a formal claim if the error remains.

Conclusion

A French tax credit refused on UK dividends after Brexit should be analysed in stages. First identify the payment: an ordinary UK dividend is not a UK REIT PID, and a broker label is not enough. Then establish French treaty residence, beneficial ownership and the gross income. Check whether any UK tax was genuinely withheld and finally borne; the former UK imputation credit is not a current treaty credit. Declare the gross payment through form 2047 and the main French return, claim only the relief allowed by the current France–UK convention, and reduce the foreign credit after any HMRC repayment. If the refusal is wrong, preserve the deadline, submit an indexed correction or réclamation contentieuse under the applicable rules, and use the domestic provisions and treaty text together. A precise payment schedule is usually the strongest answer to an imprecise refusal.

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