Part 4Savings and investment income

Chapter 3Dividends etc. from UK resident companies F1and tax credits etc. in respect of certain distributions

Annotations:
Amendments (Textual)
F1

Words in Pt. 4 Ch. 3 heading substituted (with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 2

Tax credits and payment and deduction of tax

397BF2Tax credits under section 397A: manufactured overseas dividends

1

This section applies where, under section 581 of ITA 2007, a person is treated as receiving an overseas dividend by virtue of having received a manufactured overseas dividend which is representative of an overseas dividend.

2

For the purposes of section 397A, the person is treated as receiving a relevant distribution made by a non-UK resident company F4... if, and only if, the manufactured overseas dividend is representative of such a distribution.

3

References in section 397A to the grossed up distribution have effect as if they were references to the gross amount of the overseas dividend of which the manufactured overseas dividend is representative F5(“the original dividend”), disregarding the amount of any overseas tax credit.

F33A

Section 397AA has effect as if—

a

the references in subsections (2)(a), (3) and (4)(a) to the relevant distribution were to the original dividend, and

b

the reference in subsection (2)(b) to the company that makes the relevant distribution were to the company that makes the original dividend.

4

In this section—

  • gross amount”, in relation to F6an overseas dividend, has the same meaning as in Chapter 2 of Part 11 of ITA 2007 (manufactured payments) (see section 589 of that Act),

  • manufactured overseas dividend” and “overseas tax credit” have the same meaning as in Chapter 2 of that Part (see sections 581 and 591 of that Act), and

  • overseas dividend” has the same meaning as in that Part (see section 567 of that Act).