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Manufactured overseas dividends: regulations

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The Income Tax (Manufactured Overseas Dividends) (Amendment No. 2) Regulations, SI 2011/2503, amend the principal regulations (SI 1993/2004) to provide that ‘where a stock loan of foreign shares is made via a central counterparty, manufactured overseas dividends (which compensate the lender for not receiving the real dividend) can be treated as though they had been paid directly by the stock borrower to the stock lender’. They will come into force on 10 November.