Income Tax Act 2007 section 614ZD

Treatment of recipient of manufactured payment

Section 614ZD explains how a person who receives a manufactured payment should treat that payment for income tax purposes, including two important exceptions.

• A manufactured payment received by a person is treated as though it were a real dividend or interest on the underlying securities for income tax purposes
• This treatment does not apply where the manufactured payment is already accounted for in calculating the profits of a trade carried on by the recipient
• The treatment also does not apply for the purpose of determining entitlement to double taxation relief on any dividend or interest
• Double taxation relief means any relief given under or as a result of the international tax provisions in Part 2 of the Taxation (International and Other Provisions) Act 2010