The Authorised Investment Funds (Tax) Regulations 2006 No. 964

PART 4 U.K. THE TREATMENT OF PARTICIPANTS IN AUTHORISED INVESTMENT FUNDS

CHAPTER 3 U.K. PARTICIPANTS CHARGEABLE TO CORPORATION TAX

Dividend distributions U.K.

Calculation of unfranked part of dividend distribution U.K.

49.—(1) This is how to calculate the unfranked part of the dividend distribution—

(2) In paragraph (1)—

• U = the unfranked part of the dividend distribution to the participant;

• A = the amount of the dividend distribution;

• [F1 C = such amount of the gross income as derives from income in respect of which the legal owner is charged to corporation tax, as reduced by—

  (a)

  any amount carried forward from an earlier accounting period and allowed as a deduction in computing the legal owner’s liability to corporation tax for the accounting period in which the last day of the distribution period falls, and

  (b)

  an amount equal to the legal owner’s net liability to corporation tax in respect of the gross income.]

• D = the amount of the gross income, as reduced by an amount equal to the legal owner's net liability to corporation tax in respect of the gross income.

F2 (2A) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

(3) Any reference in this regulation to the legal owner's net liability to corporation tax in respect of the gross income is a reference to the amount of the liability of the legal owner to corporation tax in respect of that gross income less the amount (if any) of any reduction of that liability which is given or falls to be given in accordance with any arrangements having effect by virtue of section 788 of ICTA (relief by agreement with other territories) or by way of a credit under section 790(1) of that Act (unilateral relief).

Textual Amendments

F1 Words in reg. 49(2) substituted (with effect in accordance with reg. 1(3) of the amending S.I.) by The Authorised Investment Funds (Tax) (Amendment) Regulations 2012 (S.I. 2012/519), regs. 1(1), 6(2)

F2 Reg. 49(2A) omitted (with effect in accordance with reg. 1(3) of the amending S.I.) by virtue of The Authorised Investment Funds (Tax) (Amendment) Regulations 2012 (S.I. 2012/519), regs. 1(1), 6(3)