Part 15U.K.Deduction of income tax at source

Chapter 9U.K.Manufactured payments

Manufactured overseas dividendsU.K.

922Manufactured overseas dividends: payments by UK residents etcU.K.

(1)This section applies if a person who pays a manufactured overseas dividend as mentioned in section 581(1)—

(a)is UK resident, or

(b)pays the manufactured overseas dividend in the course of a trade carried on through a branch or agency in the United Kingdom.

[F1(1A)But this section does not apply if—

(a)the manufactured overseas dividend is paid by a UK resident company in the course of a trade carried on through a permanent establishment in a territory outside the United Kingdom, and

(b)section 18A of CTA 2009 has effect in relation to the company for the accounting period in which it is paid.]

(2)The payer of the manufactured overseas dividend must, on making the payment, deduct from the gross amount of the manufactured overseas dividend a sum representing income tax equal to the relevant withholding tax on the gross amount.

(3)This section is subject (in particular) to—

  • section 583 (manufactured payments exceeding underlying payments), and

  • section 585 (manufactured payments: power to deal with special cases).

(4)Provision about the collection of income tax in respect of a payment from which a sum must be deducted under this section may be included in regulations under section 586 or 925.

Textual Amendments

F1S. 922(1A) inserted (19.7.2011) by Finance Act 2011 (c. 11), Sch. 13 paras. 23, 31