Commentary

C3.1911 Deemed allowable CGT loss on payment of a manufactured dividend

Capital gains tax
Capital gains tax | Commentary

C3.1911 Deemed allowable CGT loss on payment of a manufactured dividend

Capital gains tax | Commentary

C3.1911 Deemed allowable CGT loss on payment of a manufactured dividend

The legislation in this article does not apply on or after 1 January 2014. The tax treatment of manufactured payments is simplified from this date (see Division D9.7) and this capital gains treatment no longer applies.

There are three circumstances in which the payment of a manufactured dividend may give rise to a deemed loss. They all involve the transfer of UK equities from X to Y where X is required to reacquire them or has the right to require their return. They are1:

  1.  

    (a)     a 'repo' transaction (see C3.1807)

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