[F1231AB No tax credit for original owner under repurchase agreement in respect of certain manufactured dividends.U.K.
(1)A person shall not be entitled to a tax credit under section 231 F2. . . in respect of a qualifying distribution if—
[F3(a)the person is the borrower under a debtor repo or debtor quasi-repo;
(b)the qualifying distribution is a manufactured dividend paid to the borrower in consequence of that repo; and
(c)the arrangement or arrangements in relation to that repo are not such that the actual dividend which the manufactured dividend represents is receivable otherwise than by the borrower under that repo.]
[F4(1A)F5. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .]
[F6(2)In this section “debtor repo” and “debtor quasi-repo” have the meaning given by [F7Chapter 10 of Part 6 of CTA 2009 (repos)].]
(3)Subsection (4) of section 231AA applies for the purposes of this section as it applies for the purposes of that section.]
Textual Amendments
F1S. 231AB inserted (with effect in accordance with s. 102(10) of the amending Act) by Finance Act 1998 (c. 36), s. 102(2)
F2Words in s. 231AB(1) repealed (6.4.2007 with effect in accordance with s. 1034(1) of the repealing Act) by Income Tax Act 2007 (c. 3), Sch. 1 para. 25(2), Sch. 3 Pt. 1 (with Sch. 2)
F3S. 231AB(1)(a)-(c) substituted (with effect in accordance with s. 47(4) of the amending Act) by Finance Act 2007 (c. 11), Sch. 14 para. 3(2); S.I. 2007/2483, art. 3
F4S. 231AB(1A) inserted (with effect in accordance with Sch. 24 para. 1(6) of the amending Act) by Finance Act 2004 (c. 12), Sch. 24 para. 1(2)
F5S. 231AB(1A) repealed (6.4.2007 with effect in accordance with s. 1034(1) of the repealing Act) by Income Tax Act 2007 (c. 3), Sch. 1 para. 25(3), Sch. 3 Pt. 1 (with Sch. 2)
F6S. 231AB(2) substituted (with effect in accordance with s. 47(4) of the amending Act) by Finance Act 2007 (c. 11), Sch. 14 para. 3(3); S.I. 2007/2483, art. 3
F7Words in s. 231AB(2) substituted (1.4.2009 with effect in accordance with s. 1329(1) of the amending Act) by Corporation Tax Act 2009 (c. 4), Sch. 1 para. 102 (with Sch. 2 Pts. 1, 2)