Section 614ZC — Income Tax Act 2007: Treatment of payer of manufactured payment

Treatment of payer of manufactured payment 614ZC 1 This section applies where a person has a manufactured payment relationship under which a manufactured payment is paid by or on behalf of the person.

2 No deduction is allowed in respect of the manufactured payment in calculating any profits or other income of the person for income tax purposes (subject to subsection (3)).

3 Subsection (2) does not apply in relation to the person so far as the manufactured payment is brought into account under Part 2 of ITTOIA 2005 in calculating the profits of a trade carried on by the person.

4 But nothing in subsection (3) affects the question whether (apart from that provision) a deduction in calculating the profits of a trade carried on by the person is allowed.