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Manufactured overseas dividends: regulations

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The Income Tax (Manufactured Overseas Dividends) (Amendment) Regulations, SI 2011/1787, amend SI 1993/2004 to take account of the reform of the taxation of foreign permanent establishments.

‘[The amendments] will allow manufactured overseas dividends paid and received by permanent establishments outside the UK to be treated in a similar way to those paid and received by foreign companies which do not carry on a trade in the UK,’ HMRC said.