http://www.legislation.gov.uk/id/ukpga/2010/4

Part 17Manufactured payments and repos

Chapter 5Stock lending arrangements and repos

Tax credits: stock lending arrangements and repos

810No tax credits for borrower under debtor repo or debtor quasi-repo

(1)

This section applies if—

(a)

there is a debtor repo or debtor quasi-repo in respect of UK shares,

(b)

a qualifying distribution is made,

(c)

the qualifying distribution is a manufactured dividend paid to the borrower under the repo or quasi-repo in respect of the UK shares as a result of the repo or quasi-repo, and

(d)

the arrangements in relation to the repo or quasi-repo are such that the actual dividend which the manufactured dividend represents is receivable by the borrower under the repo or quasi-repo.

(2)

The borrower under the repo is not entitled to a tax credit under section 1109 (tax credits for certain recipients of qualifying distributions) in respect of the distribution.