Corporation Tax Act 2010 section 802

Powers about amounts representative of overseas dividends

Section 802 deals with the powers available to HMRC in relation to amounts that are representative of overseas dividends, in the context of double taxation relief.

• This section addresses situations where payments or amounts received by a UK company are representative of dividends from overseas companies, rather than being direct dividend payments themselves.
• It provides HMRC with specific powers to make regulations governing how such amounts should be treated for the purposes of double taxation relief.
• The aim is to ensure that relief from being taxed twice on the same income is applied correctly, even where the income takes an indirect form rather than arriving as a straightforward overseas dividend.
• The section derives from the earlier provisions found in Schedule 23A to the Income and Corporation Taxes Act 1988 and was amended by Finance Act 2013.