Part 11Manufactured payments and repos
Chapter 2Manufactured payments
Manufactured dividends on UK shares
573Manufactured dividends on UK shares
1
This section applies if a person—
a
pays another person an amount (a “manufactured dividend”) which is representative of a dividend on UK shares, and
b
does so under a requirement of an arrangement between them for the transfer of the shares.
2
The Income Tax Acts apply in relation to the recipient, and persons claiming title through or under the recipient, as if the manufactured dividend were a dividend on the shares.
3
If the payer is a UK resident company, the Income Tax Acts apply in relation to the payer as if the manufactured dividend were a dividend of the company.
4
If the payer is UK resident and is not a company, the Income Tax Acts apply in relation to the payer subject to sections 574 and 575 (allowable deductions).
5
This section is subject to—
a
section 576 (manufactured dividends on UK shares: Real Estate Investment Trusts),
b
section 583 (manufactured payments exceeding underlying payments), and
c
section 585 (power to deal with other special cases).