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Version Superseded: 01/01/2014
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There are currently no known outstanding effects for the Income Tax Act 2007, Chapter 3.
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(1)This section applies if—
(a)there is a stock lending arrangement in respect of UK shares, [F1or overseas shares,]
(b)a qualifying distribution is made to the person who is the borrower under the arrangement,
(c)the qualifying distribution is, or is a payment representative of, a dividend in respect of the F2... shares, and
(d)a manufactured dividend [F3or manufactured overseas dividend] representative of the dividend is paid by the borrower in respect of any UK shares [F4or overseas shares] in respect of which the arrangement is made.
(2)The borrower is not entitled to a tax credit under section 397(1) [F5or [F6397A(1)]] of ITTOIA 2005 (tax credits for qualifying distributions) in respect of the distribution.
(3)If the borrower is UK resident, section 399(2) of ITTOIA 2005 (recipients of qualifying distributions treated as having paid income tax at dividend ordinary rate on them) does not apply in respect of the distribution.
Textual Amendments
F1Words in s. 592(1)(a) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 27(2)(a)
F2Word in s. 592(1)(c) omitted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by virtue of Finance Act 2008 (c. 9), Sch. 12 para. 27(2)(b)
F3Words in s. 592(1)(d) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 27(2)(c)(i)
F4Words in s. 592(1)(d) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 27(2)(c)(ii)
F5Words in s. 592(2) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 27(3)
F6Word in s. 592(2) substituted (with effect in accordance with Sch. 19 para. 14 of the amending Act) by Finance Act 2009 (c. 10), Sch. 19 para. 13(b)
(1)This section applies if—
(a)there is a repo in respect of UK shares [F7or overseas shares] ,
(b)under the repo, the original owner has transferred the F8... shares to the interim holder,
(c)a qualifying distribution is made to the interim holder,
(d)the qualifying distribution is, or is a payment representative of, a dividend in respect of the F9... shares, and
(e)a manufactured dividend [F10or manufactured overseas dividend] representative of the dividend is paid by the interim holder in respect of any UK shares [F11or overseas shares] in respect of which the repo is made.
(2)The interim holder is not entitled to a tax credit under section 397(1) [F12or [F13397A(1)]] of ITTOIA 2005 (tax credits for qualifying distributions) in respect of the distribution.
(3)If the interim holder is UK resident, section 399(2) of ITTOIA 2005 (recipients of qualifying distributions treated as having paid income tax at dividend ordinary rate on them) does not apply in respect of the distribution.
Textual Amendments
F7Words in s. 593(1)(a) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 28(2)(a)
F8Word in s. 593(1)(b) omitted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by virtue of Finance Act 2008 (c. 9), Sch. 12 para. 28(2)(b)
F9Word in s. 593(1)(d) omitted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by virtue of Finance Act 2008 (c. 9), Sch. 12 para. 28(2)(b)
F10Words in s. 593(1)(e) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 28(2)(c)(i)
F11Words in s. 593(1)(e) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 28(2)(c)(ii)
F12Words in s. 593(2) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 28(3)
F13Word in s. 593(2) substituted (with effect in accordance with Sch. 19 para. 14 of the amending Act) by Finance Act 2009 (c. 10), Sch. 19 para. 13(b)
(1)This section applies if—
(a)there is a repo in respect of UK shares [F14or overseas shares] ,
(b)under the repo, the original owner has transferred the F15... shares to the interim holder,
(c)a qualifying distribution is made,
(d)the qualifying distribution is a manufactured dividend [F16or manufactured overseas dividend] paid under the repo in respect of the F17... shares by the interim holder to the original owner, and
(e)the repo is not such that the actual dividend which the manufactured dividend [F18or manufactured overseas dividend] represents is receivable by a person other than the original owner.
(2)The original owner is not entitled to a tax credit under section 397(1) [F19or [F20397A(1)]] of ITTOIA 2005 (tax credits for qualifying distributions) in respect of the distribution.
(3)If the original owner is UK resident, section 399(2) of ITTOIA 2005 (recipients of qualifying distributions treated as having paid income tax at dividend ordinary rate on them) does not apply in respect of the distribution.
Textual Amendments
F14Words in s. 594(1)(a) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 29(2)(a)
F15Word in s. 594(1)(b) omitted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by virtue of Finance Act 2008 (c. 9), Sch. 12 para. 29(2)(b)
F16Words in s. 594(1)(d) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 29(2)(c)(i)
F17Word in s. 594(1)(d) omitted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by virtue of Finance Act 2008 (c. 9), Sch. 12 para. 29(2)(c)(ii)
F18Words in s. 594(1)(e) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 29(2)(d)
F19Words in s. 594(2) inserted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 29(3)
F20Word in s. 594(2) substituted (with effect in accordance with Sch. 19 para. 14 of the amending Act) by Finance Act 2009 (c. 10), Sch. 19 para. 13(b)
In this Chapter “manufactured dividend” [F21and “manufactured overseas dividend” have] the same meaning as in Chapter 2 (see [F22sections 573(1)(a) and 581(1)(a)]).
Textual Amendments
F21Words in s. 595 substituted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 30(2)
F22Words in s. 595 substituted (21.7.2008 with effect in accordance with s. 34(2) of the amending Act) by Finance Act 2008 (c. 9), Sch. 12 para. 30(3)
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