Part 11Manufactured payments and repos
Chapter 2Manufactured payments
Special cases
584Manufactured payments less than underlying payments
1
This section applies if the sum of—
a
an amount paid by way of manufactured interest or manufactured overseas dividend, and
b
the income tax required to be accounted for and paid in connection with the making of the payment,
is less than the gross amount of the interest or overseas dividend of which it is representative.
2
For the purpose of giving relief under the Income Tax Acts in a case to which section 578 or 581 applies (manufactured interest and manufactured overseas dividends), the gross amount of the manufactured interest or manufactured overseas dividend is treated as being an amount equal to the sum of the amounts mentioned in paragraphs (a) and (b) of subsection (1).
3
Subsection (2) applies despite anything in—
a
sections 578 to 582 (main rules about manufactured interest and manufactured overseas dividends), and
b
section 589(3) (meaning of “gross amount” of manufactured overseas dividend).
4
In this section “relief” means relief by way of—
a
deduction in calculating profits or gains, or
b
deduction or set off against income.