Part 17Manufactured payments and repos
Chapter 6Interpretation of Part
813The gross amount of a manufactured overseas dividend etc
(1)
This section applies for the purposes of this Part.
(2)
The gross amount of a manufactured overseas dividend is an amount equal to the gross amount of the overseas dividend of which the manufactured overseas dividend is representative.
(3)
The gross amount of an overseas dividend is the sum of—
(a)
so much of the overseas dividend as remains after the deduction of any overseas tax chargeable on it,
(b)
the amount of any overseas tax so deducted, and
(c)
the amount of any overseas tax credit in respect of the overseas dividend.
(4)
For the purposes of this section, a credit is an overseas tax credit if it—
(a)
is a credit under the law of a territory outside the United Kingdom in respect of overseas tax, and
(b)
corresponds to a tax credit.
814Other interpretation
(1)
This section applies for the purposes of this Part.
(2)
“Overseas dividend” means any interest, dividend or other annual payment payable in respect of overseas securities.
(3)
“Overseas securities” means shares, stock or other securities issued by—
(a)
a government, local authority or other public authority of a territory outside the United Kingdom, or
(b)
another non-UK resident body of persons.
(4)
“Overseas tax” means tax under the law of a territory outside the United Kingdom.
(5)
“
” means shares in a UK resident company.(6)
In this section “securities” includes loan stock or any similar security.