F1PART 11ZAManufactured payments
614ZDTreatment of recipient of manufactured payment
1
Subsection (2) applies if a person has a manufactured payment relationship under which a manufactured payment is payable to the person.
2
For the purposes of the charge to income tax on the person's income, the Income Tax Acts apply to the person as if the manufactured payment were a dividend or interest on the securities (as the case may require).
3
Subsection (2) is subject to subsections (4) to (6).
4
Subsection (2) does not apply in relation to the person so far as the manufactured payment is brought into account under Part 2 of ITTOIA 2005 in calculating the profits of a trade carried on by the person.
5
Subsection (2) does not apply in relation to the person for the purposes of determining entitlement to double taxation relief in respect of any dividend or interest.
6
In a case in which the manufactured payment is treated as a dividend by virtue of subsection (2), the person is not entitled to a tax credit under Chapter 3 of Part 4 of ITTOIA 2005 (tax credits for certain recipients of distributions) in respect of the dividend.
7
For the purposes of this section “double taxation relief” means any relief given under or as a result of Part 2 of TIOPA 2010.
Pt. 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