Corporation Tax Act 2010

792 Company receiving manufactured overseas dividend from UK resident etc

(1) This section applies if—

(a) a person pays a manufactured overseas dividend,

(b) section 922(1) of ITA 2007 (manufactured overseas dividends: payments by UK residents etc) applies, and

(c) the amount required to be deducted as a result of that section has been deducted.

(2) Subsections (3) and (4) apply in relation to the recipient, and companies claiming title through or under the recipient, for all purposes of the Corporation Tax Acts except Part 5 of CTA 2009 (loan relationships).

(3) The manufactured overseas dividend is treated as if it were—

(a) an overseas dividend of an amount equal to the gross amount of the manufactured overseas dividend, but

(b) paid after the withholding from it, on account of overseas tax, of the amount specified in section 793.

(4) The amount mentioned in subsection (3)(b) is accordingly to be treated as an amount withheld on account of overseas tax instead of as an amount on account of income tax.

(5) Subsections (3) and (4) are subject to—

(a) section 797 (manufactured overseas dividends: amounts exceeding underlying payments), and

(b) section 798 (manufactured overseas dividends less than underlying payments).