a

pays or receives an amount (a “manufactured overseas dividend”) which is representative of an overseas dividend on overseas securities where the payment or receipt is required to be made under an arrangement for the transfer of the securities, or

b

is treated as doing so for any purposes of the Tax Acts.

6

In this section—

a

“overseas securities” means shares, stock or other securities issued by—

i

a government, local authority or other public authority of a territory outside the United Kingdom, or

ii

another body of persons not resident in the United Kingdom,

b

“overseas securities” includes shares in a company which is not resident in the United Kingdom,

c

“overseas dividend” means any interest, dividend or other annual payment payable in respect of overseas securities, and

d

“securities” includes loan stock or any similar security.