Part 1 Income Tax

SCHEDULE 29 Manufactured Payments

Section 77

Part 1 Income Tax

1

Before Part 11A of ITA 2007 insert—

“Part 11ZA
Manufactured Payments
614ZA Overview of Part

This Part deals with the application of the Income Tax Acts to manufactured payment relationships and payments representative of dividends or interest.

614ZB Key definitions

(1)     For the purposes of the Income Tax Acts a person has a manufactured payment relationship if conditions A to C are met.

(2)     Condition A is that under any arrangements—

(a)     an amount is payable by or to the person, or

(b)     any other benefit is given by or to the person (including the release of the whole or part of any liability to pay an amount).

(3)     Condition B is that the arrangements relate to the transfer of securities.

(4)     Condition C is that the amount or value of the other benefit—

(a)

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