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(1)For the purposes of the Income Tax Acts a person has a manufactured payment relationship if conditions A to C are met.
(2)Condition A is that under any arrangements—
(a)an amount is payable by or to the person, or
(b)any other benefit is given by or to the person (including the release of the whole or part of any liability to pay an amount).
(3)Condition B is that the arrangements relate to the transfer of securities.
(4)Condition C is that the amount or value of the other benefit—
(a)is representative of a dividend or interest on the securities, or
(b)will fall to be treated as representative of such a dividend or interest when it is paid or given.
(5)In subsection (2) the reference to an amount being payable, or other benefit being given, by the person includes a reference to an amount being payable, or other benefit being given, by another person on behalf of the person in question.
(6)In this Part—
“manufactured payment”, in relation to a manufactured payment relationship, means an amount, or the value of a benefit, within subsection (2), and
“securities” means—
shares in a company, and
loan stock or any similar security (whether the security is of the government of the United Kingdom, any other government, any public or local authority in the United Kingdom or elsewhere, or any other company or body).]
Textual Amendments
F1Pt. 11ZA inserted (with effect in accordance with Sch. 29 para. 51 of the amending Act) by Finance Act 2013 (c. 29), Sch. 29 para. 1
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