Part 11Manufactured payments and repos
Chapter 4Deemed manufactured payments
Repos
C1602Deemed manufactured payments: repos
1
If this section applies, the rules about manufactured payments apply as if the person from whom the securities are to be repurchased (“A”)—
a
were required, under the repo, to pay the repurchaser an amount representative of the distribution, and
b
discharged the requirement when F1the distribution was payable.
2
The amount mentioned in subsection (1)(a) is—
a
in the case of a dividend on UK shares (other than one within paragraph (b)), the amount of the dividend,
b
in the case of a dividend on UK shares so far as—
F2i
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 property rental business of members of the group,
the gross amount of the dividend,
c
in the case of a periodical payment of interest on UK securities, the gross amount of the periodical payment of interest, and
d
in the case of an overseas dividend on overseas securities, the gross amount of the overseas dividend.
F32A
In subsection (2) “gains” includes chargeable gains.
3
But if A is not the person to whom the original owner agreed to sell the securities, A is not entitled (whether as a result of the rules about manufactured payments or otherwise) to an income deduction as a result of subsection (1).
4
“Income deduction” means—
a
a deduction in calculating profits or gains for income tax purposes, or
b
a deduction in calculating net income.