After regulation 9 there shall be inserted the following regulation—

“Offsetting of tax by overseas dividend manufacturers who are not United Kingdom intermediaries9A.

(1)

An overseas dividend manufacturer who is not an approved United Kingdom intermediary shall be entitled to set off in any chargeable period amounts of overseas tax in respect of overseas dividends received by him in that chargeable period against sums due from him on account of the amounts deducted by him under paragraph 4(2) of Schedule 23A from manufactured overseas dividends paid by him in that chargeable period that are representative of those overseas dividends.

(2)

Where overseas tax referred to in paragraph (1) is set off against sums referred to in that paragraph, relief under Part XVIII of the Taxes Act may not be claimed by the overseas dividend manufacturer in respect of that overseas tax.

(3)

References in this regulation to overseas tax shall be construed in accordance with regulation 9(7).”