Explanatory Notes

Corporation Tax Act 2010

2010 CHAPTER 4

3 March 2010

Introduction

Part 17: Manufactured payments and repos

Chapter 3: Manufactured overseas dividends
Section 792: Company receiving manufactured overseas dividend from UK resident etc

2383.This section deals with the corporation tax treatment of MODs in the hands of the recipient (or, if different, the owner) when tax has been deducted under section 922(1) of ITA. It is based on paragraph 4 of Schedule 23A to ICTA.

2384.The expression “gross amount of the manufactured overseas dividend” is used in subsection (3)(a) for the first time in this Part. It is defined in section 813.

2385.The expression “overseas tax” is used in subsection (3)(b) for the first time in this Part. It is defined in section 814.