(1)This section applies if a person who pays a manufactured overseas dividend as mentioned in section 581(1)—
(a)is non-UK resident, and
(b)pays the manufactured overseas dividend otherwise than in the course of a trade carried on through a branch or agency in the United Kingdom.
(2)The recipient must account for and pay income tax in respect of the manufactured overseas dividend if the recipient—
(a)is UK resident, or
(b)is non-UK resident but receives the manufactured overseas dividend for the purposes of a trade carried on by the recipient through a branch or agency in the United Kingdom.
(3)The amount of income tax to be accounted for and paid is equal to the amount of the sum representing income tax which the payer would have been required to deduct under section 922(2) if the payer had been UK resident.
(4)If the payer would not have been required to deduct any sum under section 922(2), the recipient is not required to account for and pay any income tax under this section.
(5)This section is subject to—
section 583 (manufactured payments exceeding underlying payments),
section 585 (manufactured payments: power to deal with special cases), and
section 924 (power to reduce liability under this section).
(6)Provision about the collection of income tax required to be accounted for and paid under this section may be included in regulations under section 586.