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.