The tax treatment of the payer of a manufactured payment differs depending upon whether the payer 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 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 the:2
- Ìý
•ÌýÌýÌýÌý dividend is brought into account in calculating the profits of a trade carried on by the company3, or
- Ìý
•ÌýÌýÌýÌý manufactured dividend relates to investment business
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Web page updated on 17 Mar 2025 16:15