Corporation Tax Act 2010 section 783

Treatment of payer of manufactured dividend

Section 783 provides corporation tax relief for a company that pays a manufactured dividend, setting out the different ways relief can be given depending on the nature of the company's activities.

• A company paying a manufactured dividend can obtain corporation tax relief for the amount paid.
• The relief available depends on whether the manufactured dividend relates to a trade, to investment business, or to life assurance business carried on by the paying company.
• Where a manufactured dividend relates partly to a trade and partly to life assurance business, relief is split accordingly, with life assurance relief taking priority over trade relief to the extent it applies.
• The section ensures there is no double relief — trade relief is only excluded to the extent that life assurance relief is actually given for the same manufactured dividend.