Part 17Manufactured payments and repos
Chapter 5Stock lending arrangements and repos
Tax credits: stock lending arrangements and repos
810No tax credits for borrower under debtor repo or debtor quasi-repo
1
This section applies if—
a
there is a debtor repo or debtor quasi-repo in respect of UK shares,
b
a qualifying distribution is made,
c
the qualifying distribution is a manufactured dividend paid to the borrower under the repo or quasi-repo in respect of the UK shares as a result of the repo or quasi-repo, and
d
the arrangements in relation to the repo or quasi-repo are such that the actual dividend which the manufactured dividend represents is receivable by the borrower under the repo or quasi-repo.
2
The borrower under the repo is not entitled to a tax credit under section 1109 (tax credits for certain recipients of qualifying distributions) in respect of the distribution.