(1)This section applies if—
(a)there is a repo in respect of UK shares [F1or overseas shares] ,
(b)under the repo, the original owner has transferred the F2... shares to the interim holder,
(c)a qualifying distribution is made to the interim holder,
(d)the qualifying distribution is, or is a payment representative of, a dividend in respect of the F3... shares, and
(e)a manufactured dividend [F4or manufactured overseas dividend] representative of the dividend is paid by the interim holder in respect of any UK shares [F5or overseas shares] in respect of which the repo is made.
(2)The interim holder is not entitled to a tax credit under section 397(1) [F6or 397A(2)] of ITTOIA 2005 (tax credits for qualifying distributions) in respect of the distribution.
(3)If the interim holder is UK resident, section 399(2) of ITTOIA 2005 (recipients of qualifying distributions treated as having paid income tax at dividend ordinary rate on them) does not apply in respect of the distribution.
Textual Amendments
F1Words in s. 593(1)(a) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 28(2)(a)
F2Word in s. 593(1)(b) omitted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by virtue of Finance Act 2008 (c. 9), Sch. 12 para. 28(2)(b)
F3Word in s. 593(1)(d) omitted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by virtue of Finance Act 2008 (c. 9), Sch. 12 para. 28(2)(b)
F4Words in s. 593(1)(e) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 28(2)(c)(i)
F5Words in s. 593(1)(e) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 28(2)(c)(ii)
F6Words in s. 593(2) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 28(3)
(1)This section applies if—
(a)there is a repo in respect of UK shares [F7or overseas shares] ,
(b)under the repo, the original owner has transferred the F8... shares to the interim holder,
(c)a qualifying distribution is made,
(d)the qualifying distribution is a manufactured dividend [F9or manufactured overseas dividend] paid under the repo in respect of the F10... shares by the interim holder to the original owner, and
(e)the repo is not such that the actual dividend which the manufactured dividend [F11or manufactured overseas dividend] represents is receivable by a person other than the original owner.
(2)The original owner is not entitled to a tax credit under section 397(1) [F12or 397A(2)] of ITTOIA 2005 (tax credits for qualifying distributions) in respect of the distribution.
(3)If the original owner is UK resident, section 399(2) of ITTOIA 2005 (recipients of qualifying distributions treated as having paid income tax at dividend ordinary rate on them) does not apply in respect of the distribution.
Textual Amendments
F7Words in s. 594(1)(a) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 29(2)(a)
F8Word in s. 594(1)(b) omitted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by virtue of Finance Act 2008 (c. 9), Sch. 12 para. 29(2)(b)
F9Words in s. 594(1)(d) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 29(2)(c)(i)
F10Word in s. 594(1)(d) omitted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by virtue of Finance Act 2008 (c. 9), Sch. 12 para. 29(2)(c)(ii)
F11Words in s. 594(1)(e) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 29(2)(d)
F12Words in s. 594(2) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 29(3)