PART 1

Income tax, corporation tax and capital gains tax
CHAPTER 3

Corporation tax: general

Anti-avoidance

Treatment of the receipt of manufactured overseas dividends
22
1
Part 17 of CTA 2010 (manufactured payments and repos) is amended as follows.
2
In section 793 (company receiving manufactured overseas dividend from UK resident etc: amount treated as withheld on account of overseas tax), after subsection (7) insert—
8
If, in accordance with this section, the amount mentioned in section 792(3)(b) is not the amount deducted under section 922(2) of ITA 2007, nothing in the Tax Acts is to be read as having the effect that, in relation to the persons mentioned in section 792(2) for the purposes mentioned there, the difference between those amounts is to be regarded as an amount on account of income tax.
3
In section 812 (deemed manufactured payments: stock lending arrangements), after subsection (5) insert—
5A
Where section 792 or 794 has effect in accordance with subsection (4) or (5), nothing in the Tax Acts is to be read as having the effect that, in relation to the persons mentioned in section 792(2) or 794(2) for the purposes mentioned there, the amount that would otherwise have been treated as an amount withheld on account of overseas tax is to be regarded as an amount on account of income tax.
4
The amendments made by this section have effect in relation to overseas dividends (within the meaning of Part 17 of CTA 2010) paid on or after 15 September 2011.