Commentary on Sections Overview Overview Section 576: Manufactured dividends on UK shares: Real Estate Investment Trusts
1717.This section deals with manufactured dividends (manufactured property income dividends or MPIDs) which are representative of dividends (property income dividends or PIDs) paid by Real Estate Investment Trust companies or by principal companies of Real Estate Investment Trust groups. It is based on section 139 of, and paragraph 30 of Schedule 17 to, FA 2006.
1718.This section treats the MPID in the hands of the recipient (or, if different, the owner of the MPID) as if it was a real property income dividend. And it ensures that if an income tax payer claims title to the MPID through or under a recipient (such as a nominee), the MPID is still treated for income tax purposes as if it was a real PID even if the recipient is not an income tax payer.
1719.A dividend may be partly but not wholly a PID. Subsection (2) therefore provides that the section applies only so far as the manufactured dividend is representative of a PID.