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.