The Income Tax (Manufactured Overseas Dividends) (Amendment) Regulations 2007
These Regulations amend the Income Tax (Manufactured Overseas Dividends) Regulations 1993 (S.I. 1993/2004) (“the principal Regulations”). Regulations 3 and 4 of these Regulations amend the principal Regulations to allow a manufactured overseas dividend (a “MOD”) to be paid without deduction of tax in circumstances where a registered pension fund would have received the real overseas dividend gross and in circumstances where the MOD is linked solely to pension business for the purposes of section 438 of the Income and Corporation Taxes Act 1988. Regulation 5 of these Regulations amends regulation 7 of the principal Regulations to restrict the amount of foreign tax which may be claimed as double taxation relief. Regulations 6 to 8 of these Regulations make consequential amendments.