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The Income Tax (Manufactured Overseas Dividends) Regulations 1993

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Version Superseded: 09/12/1997

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Tax treatment of manufactured overseas dividends representative of foreign dividendsU.K.

12.[F1(1) This regulation applies to a case where a manufactured overseas dividend is paid to a collecting agent in circumstances where, had it been the overseas dividend of which it is representative, it would have been—

(a)a foreign dividend (as defined in section 18(3D) of the Taxes Act, or

(b)interest on a quoted Eurobond (as defined by section 124 of that Act) held in a recognised clearing system.]

(2) Where this regulation applies–

(a)[F2subject to paragraph (3)] deduction of an amount determined by reference to the gross amount of the manufactured overseas dividend shall be made by the F3... collecting agent from the manufactured overseas dividend on account of income tax similar to the deduction that would, in the case of the overseas dividend of which the manufactured overseas dividend is representative, have been made under [F4Chapter VIIA of Part IV of the Taxes Act]; and

[F5(b)the provisions of that Chapter relating to collecting agents shall apply in relation to amounts falling to be deducted under sub-paragraph (a) as if references in that Chapter to relevant dividends, or the proceeds of sale or other realisation of coupons for relevant dividends, included references to manufactured overseas dividends to which this regulation applies or, as the case may be, the proceeds of sale or other realisation of manufactured overseas dividends to which this regulation applies.]

[F6(3) Where a manufactured overseas dividend paid to the collecting agent on behalf of an overseas dividend manufacturer—

(a)is representative of an overseas dividend on overseas securities that are of the same kind as the overseas securities to which a manufactured overseas dividend paid by the collecting agent on behalf of that overseas dividend manufacturer relates, and

(b)is in an equivalent amount and in respect of the same dividend date as the manufactured overseas dividend paid by him on behalf of that overseas dividend manufacturer,

deduction of an amount on account of income tax shall not be made by the collecting agent under paragraph (2)(a) in respect of the manufactured overseas dividend paid to him.]

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