Regulation 4 Accountability for tax
Where—
a manufactured dividend is paid by any person other than a company resident in the United Kingdom, and
the payment is one in relation to which either the dividend manufacturer or the recipient of the payment is a person to whom paragraph (2) below applies (“the appropriate person”),
the appropriate person shall be liable to account to the Board, to the extent and in the manner specified in these Regulations, for tax as mentioned in paragraph 2(3) of Schedule 23A.
Subject to regulation 5, the appropriate person is—
where paragraph 2(5) of Schedule 23A applies in relation to the manufactured dividend, the dividend manufacturer;
where sub-paragraph (a) above does not apply in relation to the manufactured dividend and either of the conditions specified in paragraph (3) below applies, the recipient of the payment.
The conditions specified in this paragraph are—
that the recipient is a person resident in the United Kingdom;
that the recipient is a company that is not so resident but carries on a trade in the United Kingdom through a branch or agency, and the manufactured dividend is attributable to the carrying on of that trade through that branch or agency.