Corporation Tax Act 2010 section 790

Meaning of "manufactured overseas dividend"

Section 790 defines what a "manufactured overseas dividend" means for the purposes of the corporation tax rules on manufactured payments.

• A manufactured overseas dividend is a payment that is made to replicate an overseas dividend on overseas securities.
• It arises where someone is required to make a payment representative of a dividend on overseas securities to another person under an arrangement.
• The definitions of "overseas dividend" and "overseas securities" used in this section are set out in section 814 of the Act.
• This section provides the foundational definition that underpins how manufactured overseas dividends are treated for corporation tax purposes elsewhere in this Part of the Act.