574Allowable deductions: matchingU.K.
(1)This section applies if a person who pays a manufactured dividend as mentioned in section 573(1) is UK resident and is not a company.
(2)An amount equal to the lesser of—
(a)the amount of the manufactured dividend, and
(b)the amount of the dividend of which the manufactured dividend is representative,
is allowable as a deduction for income tax purposes, subject to subsection (3).
(3)It is allowable only so far as—
(a)it is not otherwise deductible, and
(b)it falls within subsection (4) or (7).
(4)An amount falls within this subsection so far as the payer—
(a)receives either the dividend which is represented by the manufactured dividend or a payment which is representative of that dividend, and
(b)is chargeable to income tax on the dividend or payment received.
(5)An amount falls within subsection (4) only if the amount of the dividend or payment received is received by the payer in—
(a)the tax year in which the payer pays the manufactured dividend, or
(b)the tax year immediately before, or immediately after, that year.
(6)An amount which falls within subsection (4) is allowable as a deduction only from the amount of the dividend or payment received on which the payer is chargeable to income tax.
(7)An amount falls within this subsection so far as the payer—
(a)is treated under section 607 (treatment of price differences under repos) as receiving a payment of interest in respect of the shares, and
(b)is chargeable to income tax on the payment.
(8)An amount which falls within subsection (7) is allowable as a deduction in calculating the net income of the payer (see Step 2 of the calculation in section 23).
(9)See section 575 for a further qualification to the rule in subsection (2).
(10)For the purposes of subsection (3)(a) an amount is deductible if it is—
(a)deductible in calculating any of the payer's profits or gains for income tax purposes, or
(b)deductible for those purposes in calculating the net income of the payer.