Income Tax Act 2007 (c. 3)

Part 11 U.K. Manufactured payments and repos

Chapter 2 U.K. Manufactured payments

Manufactured overseas dividends U.K.

[F1 581A Avoidance arrangements U.K.

(1) A manufactured overseas dividend is not deductible if it (or any part of it) is made directly or indirectly in consequence of, or otherwise in connection with, avoidance arrangements.

(2) For the purposes of subsection (1) an amount is deductible if it is—

(a) deductible in calculating any of the payer's profits or gains for income tax purposes, or

(b) deductible for those purposes in calculating the net income of the payer.]

Textual Amendments

F1 S. 581A inserted (21.7.2008 with effect in accordance with s. 63(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 23 para. 9