Part 2 Corporation Tax
Finance Act 2013 (2013 c 29) | Legislation

Part 2 Corporation Tax

2

Before Part 18 of CTA 2010 insert—

“Part 17A
Manufactured Dividends

814A Overview of Part

This Part deals with the application of the Corporation Tax Acts to manufactured dividend relationships and payments representative of dividends.

814B Key definitions

(1)     For the purposes of the Corporation Tax Acts a company has a manufactured dividend 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 company, or

(b)     any other benefit is given by or to the company (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 shares in a company.

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

(a)     is representative of a dividend on the shares, or

(b)     will fall to be treated as representative of such a dividend when it is paid or given.

(5)     In subsection (2) the reference to an amount being payable, or other benefit being given, by the company includes a reference to an amount being payable, or other benefit

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