Corporation Tax Act 2010

798 Manufactured overseas dividends less than underlying payments

(1) This section applies if the sum of—

(a) an amount paid by way of manufactured overseas dividend, and

(b) the income tax required to be accounted for and paid in connection with the making of the payment,

is less than the gross amount of the overseas dividend of which it is representative.

(2) For the purpose of giving relief under the Corporation Tax Acts in a case to which section 792 or 794 applies (manufactured overseas dividends: treatment of recipient), the gross amount of the manufactured overseas dividend is not the amount specified in section 813(2).

(3) Instead it is treated as being an amount equal to the sum of the amounts mentioned in paragraphs (a) and (b) of subsection (1).

(4) In this section “relief” means relief by way of—

(a) deduction in calculating profits or gains, or

(b) deduction from total profits.