Corporation Tax Act 2010 section 814B

Key definitions

Section 814B defines the key terms "manufactured dividend relationship", "manufactured dividend" and "the real dividend" for the purposes of the corporation tax rules on manufactured dividends.

• A company has a manufactured dividend relationship when arrangements involve payments or benefits connected to a share transfer that represent or will represent a dividend on those shares
• The arrangements must involve an amount payable by or to the company, or a benefit given by or to it — including the release of a liability to pay
• A "manufactured dividend" is the amount paid or value of the benefit provided under the arrangements, while "the real dividend" is the actual dividend on the shares that the manufactured payment represents
• Payments or benefits made by another person on behalf of the company are treated as if made by the company itself