Corporation Tax Act 2010 section 793

Section 792: amount treated as withheld

Section 793 explains how to calculate the amount of tax that is treated as having been withheld from a manufactured overseas dividend payment, for the purposes of the creditable tax rules in section 792.

• Where a company receives a manufactured overseas dividend, a certain amount of tax is treated as having been withheld from that payment under section 792.
• Section 793 provides the formula for quantifying exactly how much tax is deemed to have been withheld, ensuring consistency in how the credit is calculated.
• The calculation takes into account the provisions of section 925A of the Income Tax Act 2007, which sets out rules relevant to the deemed withholding amount on manufactured overseas dividends.
• This deemed withholding amount then feeds into the company's entitlement to double taxation relief or credit relief, as determined under the broader framework of section 792.