2379.This Chapter is concerned with:
the taxability of MODs in the hands of the recipient (or, if different, the owner);
tax relief for the payer of MODs; and
taxes management.
2380.This interpretative section is based on paragraph 4 of Schedule 23A to ICTA.
2381.The expressions “overseas dividend” and “overseas securities” are used in paragraph (a) for the first time in this Part. They are defined in section 814.
2382.This section deals with the corporation tax treatment of a payer of MODs. It is based on paragraph 4 of Schedule 23A to ICTA.
2383.This section deals with the corporation tax treatment of MODs in the hands of the recipient (or, if different, the owner) when tax has been deducted under section 922(1) of ITA. It is based on paragraph 4 of Schedule 23A to ICTA.
2384.The expression “gross amount of the manufactured overseas dividend” is used in subsection (3)(a) for the first time in this Part. It is defined in section 813.
2385.The expression “overseas tax” is used in subsection (3)(b) for the first time in this Part. It is defined in section 814.
2386.This section quantifies the amount treated as withheld under section 792(3)(b). It is based on paragraph 4A of Schedule 23A to ICTA.
2387.Subsection (2) refers to section 925A of ITA, which is based on paragraph 13 of Schedule 13 to FA 2007 and is inserted by Schedule 7 to TIOPA.
2388.This section deals with the corporation tax treatment of MODs in the hands of the recipient (or, if different, the owner) when tax has been accounted for and paid under section 923(1) of ITA. It is based on paragraph 4 of Schedule 23A to ICTA.
2389.This section provides that a MOD is exempt from corporation tax to the extent that the overseas dividend of which it is representative is (or would be) so exempt. It is based on paragraph 4 of Schedule 23A to ICTA.