Income Tax Act 2007 section 614ZB

Key definitions

Section 614ZB defines three key terms used in the manufactured payments rules: "manufactured payment relationship", "manufactured payment", and "securities".

  • A person has a manufactured payment relationship when three conditions (A to C) are all met, relating to arrangements involving payments or benefits connected to a transfer of securities
  • The payment or benefit must be representative of a dividend or interest on the securities in question, or must fall to be treated as such when paid or given
  • A manufactured payment is the amount paid or the value of the benefit provided under such arrangements, including cases where a third party pays or gives the benefit on someone's behalf
  • Securities are broadly defined to include company shares, loan stock, and any similar security, whether issued by the UK government, any other government, any public or local authority, or any company or body

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