Commentary on Sections Part 10: Miscellaneous income Overview Section 974: Charge to tax under this Chapter
2472.This section applies the charge to corporation tax to income which is treated as arising from foreign holdings where a dividend coupon attached to the holding is (a) sold or otherwise realised by a bank in the United Kingdom or (b) sold to a coupon dealer in the United Kingdom by someone other than a bank or a coupon dealer. It is based on section 18(3), (3B) and (3E) of ICTA. The corresponding rule for income tax is in section 570 of ITTOIA.
2473.Subsection (3) applies where the coupon is sold by the bank on behalf of another. See Change 75 in Annex 1.
2474.Subsection (4) applies where a person who is neither a bank nor another coupon dealer sells the dividend coupons to a coupon dealer in the United Kingdom. Section 18(3B)(b) of ICTA refers to a dealer in coupons in the United Kingdom. See Change 75 in Annex 1.