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Income Tax Act 2007

Section 941: Deemed payments to unit holders and deemed deductions of income tax

2870.This section sets out the framework of the deduction at source regime for UUTs. It is based on sections 348(1A), 349(1A) and 469 of ICTA.

2871.If the unit holder is subject to income tax, the section:

  • treats as a payment by the UUT trustees to the unit holder any grossed-up amount (for which see section 548 of ITTOIA) which is charged to tax on the unit holder under Chapter 10 of Part 4 of ITTOIA (subsection (2)); and

  • treats the trustees as having deducted, at the basic rate for the tax year, a sum representing income tax (subsection (3)).

2872.If the unit holder is subject to corporation tax, the section treats the trustees as having deducted, at the basic rate for the year, a sum representing income tax from the deemed annual payment to the unit holder (see section 469(4A) to (4D) of ICTA, inserted by Schedule 1 to this Act) (subsections (4) and (5)).

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