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49.—(1) This is how to calculate the unfranked part of the dividend distribution—
(2) In paragraph (1)—
U = the unfranked part of the dividend distribution to the participant;
A = the amount of the dividend distribution;
C = such amount of the gross income as does not derive from franked investment income, as reduced by an amount equal to the legal owner’s net liability to corporation tax in respect of the gross income;
D = the amount of the gross income, as reduced by an amount equal to the legal owner’s net liability to corporation tax in respect of the gross income.
(3) Any reference in this regulation to the legal owner’s net liability to corporation tax in respect of the gross income is a reference to the amount of the liability of the legal owner to corporation tax in respect of that gross income less the amount (if any) of any reduction of that liability which is given or falls to be given in accordance with any arrangements having effect by virtue of section 788 of ICTA (relief by agreement with other territories) or by way of a credit under section 790(1) of that Act (unilateral relief).
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