The tax treatment of manufactured payments received differs depending upon whether the recipient is a company or individual, as detailed below.
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 the (corporate) recipient is treated as receiving a dividend on the shares1.
This rule does not however apply:
- Ìý
•ÌýÌýÌýÌý if the payment is brought into account in calculating the profits of a trade carried on by the recipient2
- Ìý
•ÌýÌýÌýÌý for the purposes of determining entitlement to double taxation relief in respect of any dividend3
The
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Web page updated on 17 Mar 2025 16:08