Stock lending arrangements
592No tax credits for borrower under stock lending arrangement
(1)This section applies if—
(a)there is a stock lending arrangement in respect of UK 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 UK shares, and
(d)a manufactured dividend representative of the dividend is paid by the borrower in respect of any UK shares in respect of which the arrangement is made.
(2)The borrower is not entitled to a tax credit under section 397(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.