Part 17Manufactured payments and repos
Chapter 5Stock lending arrangements and repos
Tax credits: stock lending arrangements and repos
808No tax credits for borrower under stock lending arrangement
(1)
This section applies if—
(a)
there is a stock lending arrangement in respect of UK shares,
(b)
a qualifying distribution is made to the person who is the borrower under the arrangement,
(c)
the qualifying distribution is, or is a payment representative of, a dividend in respect of the UK shares, and
(d)
a manufactured dividend representative of the dividend is paid by the borrower in respect of any UK shares in respect of which the arrangement is made.
(2)
The borrower is not entitled to a tax credit under section 1109 (tax credits for certain recipients of exempt qualifying distributions) in respect of the distribution.