The Income Tax (Manufactured Overseas Dividends) (Amendment) Regulations 2010

Amendment of regulation 9 (offsetting of tax by overseas dividend manufacturers)

5.—(1) Amend regulation 9 (offsetting of tax by overseas dividend manufacturers) as follows.

(2) In paragraph (1), at the end insert—

“This is subject to regulation 9ZA.”.

(3) For paragraph (4B)(1) substitute—

“(4B) Where—

(a) overseas dividends or manufactured overseas dividends received by the overseas dividend manufacturer in any chargeable period fall to be matched, in accordance with regulation 10(1), against manufactured overseas dividends to which regulation 3(6), 5 or 5A applies that are paid by him in that period, and

(b) the gross amount of the overseas dividends or the manufactured overseas dividends is brought into account by the overseas dividend manufacturer as income for the purposes of income tax or corporation tax for that period,

relief under section 112 of the Taxation (International and Other Provisions) Act 2010 (deduction from income for foreign tax (instead of credit against UK tax))(2) shall be given to the overseas dividend manufacturer in respect of any tax referred to in paragraph (1A) that is attributable to those overseas dividends or manufactured overseas dividends received.”.

(1)

Paragraph (4B) of regulation 9 was inserted by S.I. 1997/988 and amended by S.I. 2007/2487.

(2)

2010 c. 8.