Corporation Tax Act 2010 (c. 4)

Part 17 U.K. Manufactured payments and repos

Chapter 5 U.K. Stock lending arrangements and repos

Tax credits: stock lending arrangements and repos U.K.

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

(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.