2

The circumstances prescribed by this paragraph are where—

a

a manufactured overseas dividend is paid to an approved United Kingdom intermediary or an approved United Kingdom collecting agent by an overseas dividend manufacturer who—

i

is resident in the United Kingdom or, if not so resident, makes the payment in the course of a trade which he carries on through a branch or agency in the United Kingdom, and

ii

is not an approved United Kingdom intermediary; and

b

the manufactured overseas dividend is not representative of the overseas dividend received by the overseas dividend manufacturer.