Statutory Instruments
INCOME TAX
Made
9th October 2003
Coming into force
1st November 2003
The Commissioners of Inland Revenue, in exercise of the powers conferred upon them by section 791 of the Income and Corporation Taxes Act 1988(1), make the following Regulations:
1. These Regulations may be cited as the Double Taxation Relief (Manufactured Overseas Dividends) (Revocation) Regulations 2003 and shall come into force on 1st November 2003.
2. The following regulations are revoked—
(a)the Double Taxation Relief (Taxes on Income) (General) (Manufactured Overseas Dividends) Regulations 1993(2);
(b)the Double Taxation Relief (Manufactured Overseas Dividends) (Amendment) Regulations 1995(3);
(c)the Double Taxation Relief (Manufactured Overseas Dividends) (Amendment) Regulations 1996(4).
Ann Chant
Dave Hartnett
Two of the Commissioners of Inland Revenue
9th October 2003
(This note is not part of the Regulations)
These Regulations revoke the Double Taxation Relief (Taxes on Income) (General) (Manufactured Overseas Dividends) Regulations 1993 (S.I. 1993/1957) (“the principal Regulations”) together with related amending regulations.
The principal Regulations provided that the Commissioners of Inland Revenue might make arrangements enabling a manufactured overseas dividend (within the meaning given by paragraph 4(1) of Schedule 23A to the Income and Corporation Taxes Act 1988 (c. 1) (“Schedule 23A”)) to be paid without deduction of tax. The main condition for the making of such arrangements was that the person to whom or for whose benefit the payment was made was resident in an overseas territory with which the United Kingdom had made arrangements for the relief of double taxation which provided exemption from United Kingdom tax in respect of such income.
The principal Regulations are being revoked in consequence of amendments being made to the Income Tax (Manufactured Overseas Dividends) Regulations 1993 (S.I. 1993/2004) which have the effect of removing the requirements to account for and pay tax in respect of such dividends where payment is to a person who is not a United Kingdom recipient (within the meaning given by paragraph 4(3A) of Schedule 23A).