Commentary on Sections Structure of Chapters Overview Section 570: Charge to tax under Chapter 13
2229.This section charges to tax 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. The term “foreign holdings” is defined in section 571. The section is based on section 18 of ICTA.
2230.Subsection (3) sets out the first circumstance in which income is treated as arising from foreign holdings. This is where the UK office of a bank pays over the proceeds of a sale or realisation of dividend coupons or carries those proceeds to an account. Section 18(3B)(a) of ICTA refers simply to “a bank in the United Kingdom”. See Change 103 in Annex 1.
2231.Subsection (4) sets out the second circumstance. This is 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 103 in Annex 1.