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