Commentary

D9.701 What is a manufactured payment?

Corporate tax
Corporate tax | Commentary

D9.701 What is a manufactured payment?

Corporate tax | Commentary

Division D9.7     Manufactured dividends and interest

For updates affecting this Division please see Part D0 Updates

Tax treatment of manufactured dividends and interest

D9.701 What is a manufactured payment?

Manufactured payments are, broadly, payments representative of UK dividends, interest or overseas dividends paid under contracts or other arrangements for the transfer of securities.

The strict definition of manufactured payments for companies and individuals is detailed below, together with a summary of typical transactions that will fall within the manufactured payments regime.

Companies

A manufactured dividend relationship for corporation tax purposes exists where all the following conditions are met1:

  1.  

    •     under any arrangements an amount is payable by or to the company, or any other benefit is given by or to the company (including the release of the whole or part of any

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