SCHEDULES
SCHEDULE 23Manufactured payments: anti-avoidance
9Section 581A
After section 581 insert—
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.