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Section 581A Avoidance arrangements

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Amendments

Section 581A inserted by Finance Act 2008 section 63 and Schedule 23 para 9 in relation to manufactured payments (including deemed manufactured payments) made (or treated as made) on or after 31 January 2008.

(1) A manufactured overseas dividend is not deductible if it (or any part of it) is made directly or indirectly in consequence of, or otherwise in connection with, avoidance arrangements.

(2) For the purposes of subsection (1) an amount is deductible if it is—

(a) deductible in calculating any of the payer’s profits or gains for income tax purposes, or

(b) deductible for those purposes in calculating the net income of the payer.

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