Section 397B — Finance Act 2008: Tax credits under section 397A: manufactured overseas dividends

Tax credits under section 397A: manufactured overseas dividends 397B 1 This section applies where, under section 581 of ITA 2007, a person is treated as receiving an overseas dividend by virtue of having received a manufactured overseas dividend which is representative of an overseas dividend.

2 For the purposes of section 397A, the person is treated as receiving a relevant distribution made by a non-UK resident company that is not an offshore fund if, and only if, the manufactured overseas dividend is representative of such a distribution.

3 References in section 397A to the grossed up distribution have effect as if they were references to the gross amount of the overseas dividend of which the manufactured overseas dividend is representative, disregarding the amount of any overseas tax credit.

4 In this section— “ gross amount ”, in relation to a manufactured overseas dividend, has the same meaning as in Chapter 2 of Part 11 of ITA 2007 (manufactured payments) (see section 589 of that Act), “ manufactured overseas dividend ” and “ overseas tax credit ” have the same meaning as in Chapter 2 of that Part (see sections 581 and 591 of that Act), and “ overseas dividend ” has the same meaning as in that Part (see section 567 of that Act).