Corporation Tax Act 2010 (c. 4)

Part 17 U.K. Manufactured payments and repos

Chapter 4 U.K. Further provision about manufactured payments

Miscellaneous U.K.

802 Powers about amounts representative of overseas dividends U.K.

(1) The Treasury may by regulations make provision as mentioned in subsections (2) and (3) about prescribed cases where a person—

(a) pays or receives an amount representative of an overseas dividend, or

(b) is treated as doing so for any purposes of this Chapter or Chapter 3, or of regulations made under this Chapter.

(2) The regulations may provide for removing or reducing any right of the person to claim relief under Part 2 of TIOPA 2010 (double taxation relief).

(3) The regulations may provide for adjusting a relevant amount by reference to a provision that has effect under the law of a territory outside the United Kingdom.

(4) A “relevant amount” is an amount which is treated for prescribed purposes of the Corporation Tax Acts as the amount paid or payable to a person in respect of a relevant transaction.

(5) A “relevant transaction” is a sale, repurchase or other transfer of the overseas securities to which the amount mentioned in subsection (1)(a) relates.