Income Tax Act 2007 section 843

Restriction of deductions for annual payments

Section 843 prevents annual payments made in return for dividends or non-taxable consideration from being deducted when calculating a person's income from any source.

• Annual payments made for dividends or non-taxable consideration cannot be deducted from income
• The restriction applies regardless of the source of income against which the deduction might be claimed
• These payments are also excluded from being qualifying annual payments, so no tax is deducted at source on them
• No relief is available for these payments under any route, including the annual payments and patent royalties provisions