581AAvoidance arrangements

1

A manufactured overseas dividend is not deductible if it (or any part of it) is made directly or indirectly in consequence of, or otherwise in connection with, avoidance arrangements.

2

For the purposes of subsection (1) an amount is deductible if it is—

a

deductible in calculating any of the payer's profits or gains for income tax purposes, or

b

deductible for those purposes in calculating the net income of the payer.