Part 11Manufactured payments and repos
Chapter 3Tax credits: stock lending arrangements and repos
Repos
594No tax credits for original owner under repo
1
This section applies if—
a
there is a repo in respect of UK shares F1or overseas shares ,
b
under the repo, the original owner has transferred the F2... shares to the interim holder,
c
a qualifying distribution is made,
d
e
the repo is not such that the actual dividend which the manufactured dividend F5or manufactured overseas dividend represents is receivable by a person other than the original owner.
2
3
If the original owner 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.