Part 11Manufactured payments and repos

Chapter 4Deemed manufactured payments

Repos

C1603Deemed deductions of tax

1

This section applies if—

a

an amount is treated as paid under section 602(1)(b) (deemed manufactured payments), and

b

as a result, one of these sections applies—

i

section 918 (deduction of income tax at source: manufactured dividends on UK shares: Real Estate Investment Trusts),

ii

section 919 (deduction of income tax at source: manufactured interest on UK securities),

iii

section 922 (deduction of income tax at source: manufactured overseas dividends).

2

So far as the deemed payment is representative of a dividend on UK shares—

F1a

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

b

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,

any deduction which (as a result of section 918) is required to be made out of the gross amount of the payment is treated as made.

3

If the deemed payment is representative of a periodical payment of interest on UK securities, any deduction which (as a result of section 919) is required to be made out of the gross amount of the payment is treated as made.

4

If the deemed payment is representative of an overseas dividend on overseas securities, any deduction which (as a result of section 922) is required to be made out of the gross amount of the payment is treated as made.

F25

In subsection (2) “gains” includes chargeable gains.