{
  "url": "https://openlegislation.uk/income-tax-manufactured-overseas-dividends-amendment-regulations-2010/note",
  "json_url": "https://openlegislation.uk/income-tax-manufactured-overseas-dividends-amendment-regulations-2010/note.json",
  "legislation": "uksi/2010/925",
  "legislation_title": "The Income Tax (Manufactured Overseas Dividends) (Amendment) Regulations 2010",
  "legislation_url": "https://openlegislation.uk/income-tax-manufactured-overseas-dividends-amendment-regulations-2010",
  "path": "note",
  "kind": "note",
  "number": null,
  "heading": "Explanatory note",
  "text": "(This note is not part of the Regulations)\nThese Regulations amend the Income Tax (Manufactured Overseas Dividends) Regulations 1993 (S.I. 1993/2004) (“the principal Regulations”).\nRegulation 1 provides for citation, commencement and effect.\nRegulation 2 introduces the amendments to the principal Regulations.\nRegulation 3 amends regulation 2 (interpretation) to insert a definition of “gross amount of the overseas dividend”.\nRegulation 4 amends regulation 6A (reduction of tax payable under paragraph 4(3) of Schedule 23A) to extend the restriction of double taxation relief under Part 2 of the Taxation (International and Other Provisions) Act 2010 (previously Part 18 of the Income and Corporation Taxes Act 1988) in relation to relief given under section 112 of that Act (deduction from income for foreign tax (instead of credit against UK tax)) (previously section 118 of the Income and Corporation Taxes Act 1988) where overseas tax was charged on the manufactured overseas dividend concerned.\nRegulation 5 amends regulation 9 (offsetting of tax by overseas dividend manufacturers). Regulation 9 provides that an approved United Kingdom intermediary shall be entitled to set off tax on overseas dividends and manufactured overseas dividends received in any chargeable period against tax on approved manufactured overseas dividends paid in that period. The amendment to paragraph (1) makes this entitlement subject to new regulation 9ZA. Paragraph (4B) is amended to restrict double taxation relief under section 112 of the Taxation (International and Other Provisions) Act 2010 in the case of certain overseas dividends or manufactured overseas dividends which are matched against each other under regulation 10 of the principal Regulations. The amendment ensures such elief is only available if the gross amount of the dividend is brought into account.\nRegulation 6 inserts a new regulation 9ZA. This provision restricts the entitlement to offsetting where the overseas dividends or manufactured overseas dividends are not matched against each other under regulation 10 of the principal Regulations to cases where the gross amount of the dividend is brought into account, either in accordance with generally accepted accounting practice or by election under this provision.\nRegulation 7 amends regulation 9A (offsetting of tax by overseas dividend manufacturers who are not United Kingdom Intermediaries) to restrict the availability of relief under section 112 of the Taxation (International and Other Provisions) Act 2010 by overseas dividend manufacturers who are not approved United Kingdom intermediaries to cases where the gross amount of the overseas dividends or manufactured overseas dividends is brought into account.\nA full Impact Assessment has not been produced for this instrument as no impact on the private or voluntary sectors is foreseen.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/2010/925/note",
    "retrieved_at": "2026-10-29T02:46:15.522273+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}