holds himself out at all normal times in compliance with the rules of the Stock Exchange as willing to buy and sell shares, stock or other securities of the kind concerned at a price specified by him, and

is recognised as doing so by the Council of the Stock Exchange,

shares, stock or other securities issued by a government or public or local authority of a territory outside the United Kingdom or by any other body of persons not resident in the United Kingdom; and

quoted F4Eurobonds (as defined by section 124) held in a recognised clearing system ;

any manufactured dividend, manufactured interest or manufactured overseas dividend paid in connection with an unapproved stock lending arrangement, and

by changing the definition for the time being of “market maker”; or

by changing the definition for the time being of “unapproved manufactured payment”.

as if the manufactured dividend were a dividend on the United Kingdom equities,

as if any amount required in consequence of section 737 to be deducted by the dividend manufacturer on account of income tax in respect of the gross amount of the manufactured dividend were required to be accounted for by him as advance corporation tax in respect of the dividend, and

as if any certificate of deduction of tax required in consequence of that section to be issued in connection with the manufactured dividend were the tax credit certificate that would have been issued had the manufactured dividend in fact been a dividend on the United Kingdom equities.

the dividend of which the manufactured dividend is representative is a foreign income dividend, and

the dividend manufacturer is a company resident in the United Kingdom,

the dividend of which the manufactured dividend is representative is a foreign income dividend, and

the dividend manufacturer is not a company resident in the United Kingdom (so that, were the dividend of which the manufactured dividend is representative not a foreign income dividend, section 737 would apply in relation to the dividend manufacturer),

in relation to the interest manufacturer, for all the purposes of the Tax Acts except the determination of whether a deduction of tax is liable to be made on the making of the manufactured payment, and

in relation to the recipient and all persons claiming title through or under him, for all the purposes of those Acts,

is resident in the United Kingdom, but

is not a company,

the dividend manufacturer were a company resident in the United Kingdom, and

the manufactured dividend were a distribution by that company.

deductible in computing the amount of any of the dividend manufacturer’s profits or gains for the purposes of income tax or corporation tax; or

deductible for those purposes from the total income or, as the case may be, total profits of the dividend manufacturer.

the deemed dividend of the dividend manufacturer were itself a foreign income dividend; and

that foreign income dividend were one in respect of which the dividend manufacturer is not liable to make any payment of advance corporation tax.

the Tax Acts shall have effect, in relation to the recipient and any persons claiming title through or under him, as if the dividend on the United Kingdom equities which the recipient is treated as having received were a foreign income dividend;

there shall be no requirement for any person to account for tax in respect of that manufactured dividend by virtue of paragraph 2(3)(a) above;

any deduction made in respect of the manufactured dividend under paragraph 2A(1) above shall be made without including an amount equal to the notional ACT in the deduction; and

the dividend manufacturer, on paying the manufactured dividend in any case falling within sub-paragraph (3) below, shall provide the recipient with a statement in writing setting out the matters specified in sub-paragraph (4) below.

the amount of the manufactured dividend;

the date on which it is paid;

the fact that the dividend carries no entitlement to a tax credit; and

in the case of a manufactured dividend which is representative of a qualifying distribution to which Schedule 7 to the Finance Act 1997 applies, the fact that the distribution is a foreign income dividend by virtue of paragraph 2(1) of that Schedule.

the amount which is to be deducted from that gross amount on account of income tax shall be an amount equal to the relevant withholding tax on that gross amount; and

in the application of sections 338(4)(a) and 350(4) in relation to manufactured overseas dividends the references to Schedule 16 shall be taken as references to dividend manufacturing regulations;

he is resident in the United Kingdom; or

he is not so resident but receives that dividend for the purposes of a trade carried on through a branch or agency in the United Kingdom.

the making of the manufactured overseas dividend; or

the overseas dividend of which the manufactured overseas dividend is representative.

the manufactured overseas dividend shall be treated in relation to the recipient, and all persons claiming title through or under him, as if it were an overseas dividend of an amount equal to the gross amount of the manufactured overseas dividend, but paid after the withholding therefrom, on account of overseas tax, of the amount deducted under sub-paragraph (2) above; and

the amount so deducted shall accordingly be treated in relation to the recipient, and all persons claiming title through or under him, as an amount so withheld instead of as an amount on account of income tax.

the gross amount of a manufactured overseas dividend is an amount equal to the gross amount of that overseas dividend of which the manufactured overseas dividend is representative, as mentioned in sub-paragraph (1) above; and

the rates at which overseas tax would have fallen to be deducted, and

the rates of overseas tax credits,

amounts of overseas tax in respect of overseas dividends received by him in that chargeable period, amounts of overseas tax charged on, or in respect of, the making of manufactured overseas dividends so received by him and amounts deducted under sub-paragraph (2) above from any such manufactured overseas dividends; and

the sums due from him on account of the amounts deducted by him under sub-paragraph (2) above from the manufactured overseas dividends paid by him in that chargeable period.

a foreign dividend (as defined by section 18(3D)), or

interest on a quoted Eurobond (as defined by section 124) held in a recognised clearing system,

where the deduction is made in respect of a manufactured overseas dividend that is treated as paid under paragraph 13(1) of Schedule 13 to FA 2007 (sale and repurchase of securities), to amount A, and

otherwise, to the amount deducted under section 922(2) of ITA 2007.

in a case to which sub-paragraph (3) applies, the amount deducted under section 922(2) of ITA 2007,

in any other case, nil.

an amount is actually paid by way of manufactured overseas dividend,

the amount so paid equals the relevant net amount, and

it is reasonable to assume that, in deciding the repurchase price of the securities, no account was taken of the fact that the amount would be so paid.

an amount is actually paid by way of manufactured overseas dividend,

the amount so paid exceeds the relevant net amount, and

it is reasonable to assume that, in deciding the repurchase price of the securities, no account was taken of the fact that the amount would be so paid.

the gross amount of the overseas dividend of which the manufactured overseas dividend is representative, less

the amount deducted under section 922(2) of ITA 2007.

to a dividend or a periodical payment of interest as the registered holder of the securities, or

to payment, whether directly or indirectly, of any such dividend or interest from a person from whom he acquired the securities or to whom he transferred them,

paragraphs 2, 3 and 4 above and section 737 shall not apply in relation to the manufactured payment,

the dividend or interest shall be treated for all purposes of the Tax Acts as the income of the recipient and not as the income of the payment manufacturer F33and shall also be treated, in the case of interest the recipient of which is a company, as if for the purposes of Chapter II of Part IV of the Finance Act 1996 it were interest under a loan relationship to which the company is a party, F28. . .

the manufactured payment shall not be regarded as the income of the recipient,F29 and

relief shall not be given under any provision of the Tax Acts to the payment manufacturer in respect of the manufactured payment.

any dividend or interest would, apart from the application or, as the case may be, the subsequent application of this sub-paragraph, be treated by virtue of any provision of this paragraph as the income of a person (the “subsequent manufacturer”) who is a party to a further contract or other arrangements for the transfer of securities, and

under that contract or those arrangements, the subsequent manufacturer is required to pay to the other party (the “subsequent recipient”) an amount representative of the dividend or interest (the “subsequent manufactured payment”),

paragraphs 2, 3 and 4 above and section 737 shall not apply in relation to the manufactured payment or any subsequent manufactured payment;

the dividend or interest shall be treated for all purposes of the Tax Acts as the income of the subsequent recipient (or, on a second or subsequent application of sub-paragraph (3) above, the last of them) and not as the income of any other person F33and shall also be treated, in the case of interest the recipient of which is a company, as if for the purposes of Chapter II of Part IV of the Finance Act 1996 it were interest under a loan relationship to which the company is a party; F28. . .

neither the manufactured payment nor any subsequent manufactured payment shall be regarded as the income of the recipient or of any subsequent recipient;F30 and

relief shall not be given under any provision of the Tax Acts to the payment manufacturer or any subsequent manufacturer in respect of the manufactured payment or any subsequent manufactured payment.

the dividend or interest is an overseas dividend,

the payment manufacturer or a subsequent manufacturer is resident in the United Kingdom but the recipient or a subsequent recipient is not so resident, and

the rates of overseas tax or overseas tax credit applicable to the overseas dividend in relation to the payment manufacturer or subsequent manufacturer falling within paragraph (b) above are different from what they would have been in relation to the recipient or subsequent recipient falling within that paragraph, had the overseas dividend been paid directly to him,

deduction in computing profits or gains; or

deduction or set off against income or total profits.

shall not be set against any liability of the company to corporation tax as mentioned in section 239;

shall not be surrendered under, or otherwise treated as mentioned in, section 240; and

shall not be utilised in any other way for the purposes of the Tax Acts;

an amount paid by way of manufactured dividend would exceed the amount of the dividend of which it is representative, or

for the amount of the fee to be determined in accordance with the regulations, and

for such of the persons mentioned in that paragraph as may be prescribed to be treated as paying or, as the case may be, as receiving the fee,

the gross amount of the manufactured interest or manufactured overseas dividend shall be taken to be an amount equal to the aggregate referred to in sub-paragraph (1)(b) above, except where paragraph 6 above applies, and

where paragraph 6 above applies, the gross amount of the manufactured interest or manufactured overseas dividend shall be taken to be only the amount referred to in sub-paragraph (1)(b)(i) above,

deduction in computing profits or gains; or

deduction or set off against income or total profits.

a manufactured payment falls to be made by a company in an accounting period in pursuance of any arrangements (see sub-paragraphs (9) and (10) for definitions), and

the arrangements have an unallowable purpose at any time (see sub-paragraphs (3) to (5)).

the arrangements,

any related transaction (see sub-paragraphs (6) and (7)), or

any transaction in pursuance of the arrangements,

any arrangements,

any related transaction in the case of any arrangements, or

any transaction in pursuance of any arrangements,

the likely effect of the transactions, and

the circumstances in which the transactions are entered into or effected,

are not between the same parties, or

are not between the parties to the arrangements.

section 75(4)(b) (expenses of management of companies with investment business: unallowable purposes),

section 76(4)(d) (expenses of insurance companies: unallowable purposes),

paragraph 13 of Schedule 9 to the Finance Act 1996 (loan relationships with unallowable purposes),

such manufactured dividends, manufactured interest or manufactured overseas dividends as may be prescribed,

such persons who receive, or become entitled to receive, manufactured dividends, manufactured interest or manufactured overseas dividends as may be prescribed, or

such dividend manufacturers, interest manufacturers or overseas dividend manufacturers as may be prescribed,

for any entitlement of that person to claim relief under Part XVIII to be extinguished or reduced to such extent as may be found under the regulations; and

for the adjustment, by reference to any provision having effect under the law of a territory outside the United Kingdom, of any amount falling to be taken, for any prescribed purposes of the Tax Acts or the 1992 Act, to be the amount paid or payable by or to any person in respect of any sale, repurchase or other transfer of the overseas securities to which the payment relates.

the accounts and other records which are to be kept,

the vouchers which are to be issued or produced,

the returns which are to be made,

the manner in which amounts required to be deducted or accounted for under or by virtue of this Schedule on account of tax are to be accounted for and paid,

make provision for prescribed provisions of the Management Act to apply in relation to manufactured dividends, manufactured interest or manufactured overseas dividends with such modifications, specified in the regulations, as the Treasury think fit;

make such further provision with respect to the administration, assessment, collection and recovery of amounts required to be deducted or accounted for under or by virtue of this Schedule on account of tax as the Treasury think fit.