Income Tax Act 2007 section 582

Powers about manufactured overseas dividends

Section 582 deals with the Treasury's powers to make regulations concerning double taxation relief in relation to manufactured overseas dividends.

• This section addresses the interaction between manufactured overseas dividends and double taxation relief.
• Manufactured overseas dividends arise when securities are lent or sold with an agreement to repurchase, and a payment is made to replicate the overseas dividend the original holder would have received.
• The Treasury has the power to make regulations that govern how double taxation relief applies in these circumstances.
• The provision derives from the earlier rules in Schedule 23A to the Income and Corporation Taxes Act 1988.