Introduction Summary
1.Section 36 and Schedule 11 introduce legislation (i) to prevent the use of manufactured payments instead of real overseas dividends in order to sidestep existing anti-avoidance defences in the double tax relief (DTR) legislation, (ii) to ensure that a person may only deduct foreign tax from any foreign income where he has not already reduced his income by reference to the foreign tax, and (iii) to reaffirm the scope of the targeted DTR anti-avoidance rule.