Part 11Manufactured payments and repos

Chapter 2Manufactured payments

Manufactured dividends on UK shares

576Manufactured dividends on UK shares: Real Estate Investment Trusts

(1)

This section applies (instead of section 573(2) and (3)) if—

(a)

a person pays a manufactured dividend as mentioned in section 573(1), and

(b)

the manufactured dividend is representative of a dividend which is—

F1(i)

paid by a company UK REIT in respect of profits or gains (or both) of the company’s property rental business, or

(ii)

paid by the principal company of a group UK REIT in respect of profits or gains (or both) of members of the group as shown in the financial statement under section 532(2)(b) of CTA 2010 (statement of group’s property rental business in UK).

(2)

This section applies only so far as the manufactured dividend is representative of such a dividend.

(3)

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 to which F2section 548 of CTA 2010 applied (distributions treated as UK property business profits).

(4)

This section is subject to—

(a)

section 583 (manufactured payments exceeding underlying payments), and

(b)

section 585 (power to deal with other special cases).

F3(5)

In subsection (1) “gains” includes chargeable gains.