Income Tax Act 2007 section 567

Meaning of "overseas shares", "overseas securities" and "overseas dividend"

Section 567 defines the terms "overseas shares", "overseas securities" and "overseas dividend" for the purposes of the provisions dealing with manufactured overseas dividends.

• "Overseas shares" are shares in a non-UK resident company whose dividends would be taxable as relevant foreign income if received by a UK resident individual.
• "Overseas securities" are securities issued by a non-UK resident entity where the interest would similarly be taxable as relevant foreign income for a UK resident individual.
• An "overseas dividend" is any interest, dividend or other annual payment paid on overseas shares or overseas securities.
• These definitions are important because they determine which payments fall within the manufactured overseas dividends rules when shares or securities are subject to stock lending or repo arrangements.