Commentary

D9.703 Manufactured payments—Treatment of payer

Corporate tax
Corporate tax | Commentary

D9.703 Manufactured payments—Treatment of payer

Corporate tax | Commentary

D9.703 Manufactured payments—Treatment of payer

The tax treatment of the payer of a manufactured payment differs depending upon whether the payer is a company or individual, as detailed below.

Corporates

Manufactured dividend

Where a company has a manufactured dividend relationship (D9.701) and pays a manufactured dividend under the arrangement, the general rule is that no income deduction is allowed in respect of the manufactured dividend for corporation tax purposes1.

However the general rule will not apply and instead the manufactured dividend is treated as a trading expense, an expense of management or deemed BLAGAB management expense (as appropriate) of the company for the accounting period if

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