171. Manufactured payments and dividends.

Part 11ZA of the Income Tax Act 20071 deals with the application of the Income Tax Acts to manufactured payment relationships and payments representative of dividends or interest2, and Part 17A of the Corporation Tax Act 20103 deal with the application of the Corporation Tax Acts to manufactured dividend relationships and payments representative of dividends4.

For the purposes of the Income Tax Acts a person has a manufactured payment relationship if conditions A to C are met5, as follows:

  1.  

    (1)     condition A, that under any arrangements:

    1.  

      (a)     an amount is payable by or to the person6; or

    2.  

      (b)     any other