590Meaning of “relevant withholding tax”U.K.
(1)This section applies for the purposes of this Chapter.
(2)“Relevant withholding tax”, in relation to the gross amount of a manufactured overseas dividend, means an amount of income tax representative of the sum of—
(a)any amount that would have been deducted by way of overseas tax from an overseas dividend on the overseas securities of the same gross amount as the manufactured overseas dividend, and
(b)the amount of any overseas tax credit in respect of such an overseas dividend.
(3)The Treasury may by regulations make provision about the rates of relevant withholding tax which are to apply in relation to manufactured overseas dividends in relation to different overseas territories.
(4)The Treasury must, in prescribing these rates, have regard to—
(a)the rates at which overseas tax would have fallen to be deducted, and
(b)the rates of overseas tax credits,
in overseas territories, or in the particular overseas territory, in respect of payments of overseas dividends on overseas securities.