Corporation Tax Act 2010 section 813

The gross amount of a manufactured overseas dividend etc

Section 813 defines how to determine the gross amount of a manufactured overseas dividend for corporation tax purposes, ensuring that any tax deducted or withheld is added back to arrive at the full pre-tax figure.

• A manufactured overseas dividend (MOD) is a payment that mirrors a real overseas dividend, made under arrangements for the transfer of overseas securities.
• The gross amount of a MOD is calculated by adding back any tax deducted or withheld from the payment, so that the figure used for tax purposes reflects the full amount before any deductions.
• This treatment parallels the way real overseas dividends are grossed up — the actual dividend received plus any overseas tax withheld equals the gross dividend.
• The section draws on earlier provisions in ICTA (sections 736B, 736C and Schedule 23A) and TCGA (section 263B), consolidated and updated by the Corporation Tax Act 2010 and subsequently amended by Finance Act 2013.

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