Part 15Deduction of income tax at source
Chapter 9Manufactured payments
Manufactured overseas dividends
925Power to provide set-off entitlement
1
The Treasury may by regulations provide for a person who, in any prescribed period, pays a manufactured overseas dividend as mentioned in section 581(1) to be entitled—
a
to set off relevant amounts of tax suffered against relevant tax liabilities, and
b
to account to the Commissioners for Her Majesty’s Revenue and Customs for the balance or claim credit in respect of it.
2
Regulations under this section may—
a
prescribe the circumstances in which relevant amounts of tax suffered may be set off against relevant tax liabilities, and
b
provide for relevant amounts of tax suffered to be set off against relevant tax liabilities in accordance with the regulations and so far as prescribed.
3
“Relevant amounts of tax suffered” are—
a
amounts of overseas tax in respect of overseas dividends received by the person in the prescribed period,
b
amounts of overseas tax charged on, or in respect of, the making of manufactured overseas dividends received by the person in the prescribed period, and
c
amounts—
i
deducted as a result of section 922, or
ii
accounted for and paid as a result of section 923,
from any manufactured overseas dividends received by the person in the prescribed period.
4
“Relevant tax liabilities” are sums due from the person on account of the amounts deducted by the person as a result of section 922 from the manufactured overseas dividends paid by the person in the prescribed period.
5
In this section—
“credit” includes credit against corporation tax, and
“prescribed” means prescribed in regulations under this section.