CFM74360 - Other tax rules on corporate finance: manufactured payments: manufactured overseas dividends
This guidance applies to manufactured payments made before 1 January 2014, when the tax rules were simplified. For manufactured payments made on or after 1 January 2014, see CFM74430.
»Ê¹ÚÌåÓýapp rules for manufactured overseas dividends (MODs) are in ITA07/S581 and S582, ITA07/S922-S925 and CTA10/PT17/CH3 and regulations made under them. »Ê¹ÚÌåÓýapp rules are more complex than the rules for the other types of manufactured payments and are set out in CFM74370 to CFM74420.
»Ê¹ÚÌåÓýapp rules provide a regime covering both treatment of MODs for tax purposes and setting out a tax deduction regime. Detailed guidance on the operation of the rules is available in the guidance notes at , which should be consulted where detailed guidance is needed on how the rules operate in particular circumstances.
Definition of ‘overseas securities�
‘Overseas securities� are shares, stock, or other securities issued by a government or public or local authority of a territory outside the UK or by any other body of persons not resident in the UK. This includes both overseas shares and overseas debt securities.
»Ê¹ÚÌåÓýapp terms UK manufacturer and UK recipient refer to a manufacturer or recipient who is resident in the UK or who pays or receives the manufactured overseas dividend in the course of carrying on a trade in the UK through a permanent establishment.