Part 17Manufactured payments and repos
Chapter 4Further provision about manufactured payments
Miscellaneous
802Powers about amounts representative of overseas dividends
(1)
The Treasury may by regulations make provision as mentioned in subsections (2) and (3) about prescribed cases where a person—
(a)
pays or receives an amount representative of an overseas dividend, or
(b)
is treated as doing so for any purposes of this Chapter or Chapter 3, or of regulations made under this Chapter.
(2)
The regulations may provide for removing or reducing any right of the person to claim relief under Part 2 of TIOPA 2010 (double taxation relief).
(3)
The regulations may provide for adjusting a relevant amount by reference to a provision that has effect under the law of a territory outside the United Kingdom.
(4)
A “relevant amount” is an amount which is treated for prescribed purposes of the Corporation Tax Acts as the amount paid or payable to a person in respect of a relevant transaction.
(5)
A “relevant transaction” is a sale, repurchase or other transfer of the overseas securities to which the amount mentioned in subsection (1)(a) relates.
803Power to deal with special cases
(1)
The Treasury may by regulations make provision about—
(a)
such manufactured dividends or manufactured overseas dividends as may be prescribed,
(b)
such persons who receive, or become entitled to receive, manufactured dividends or manufactured overseas dividends as may be prescribed, or
(c)
such payers of manufactured dividends or manufactured overseas dividends as may be prescribed.
(2)
The provision which may be made is for any prescribed manufactured dividend, manufactured overseas dividend or person to be treated, in prescribed circumstances, otherwise than as mentioned in any of sections 783 to 788, 791, 792, 794 and 795 (rules about manufactured dividends and manufactured overseas dividends), for any prescribed purposes of the Corporation Tax Acts.
804Regulation-making powers: general
(1)
Regulations made under Chapter 2 or this Chapter may make different provision for different cases.
(2)
In this Chapter “prescribed” means prescribed in regulations under this Chapter.