Recharacterisation of certain transactions - Consolidated groups of companies - Treatment of foreign dividends
FM 25: Reduction in payments for foreign dividends
You could also call this:
“This provision about reducing foreign dividend payments no longer applies”
This part of the law was about reducing payments for foreign dividends. It was part of the rules for how foreign dividends are treated in the Income Tax Act 2007. However, this section no longer applies. It was removed from the law on 6 October 2009, but the change was meant to work from 1 April 2009. This means that since then, there have been no special rules in this section about reducing payments for foreign dividends.
“Tax losses can no longer be used to pay foreign dividend taxes”
Part F
Recharacterisation of certain transactions
Consolidated groups of companies:
Treatment of foreign dividends
FM 25Reduction in payments for foreign dividends (Repealed)
Notes
Section FM 25: repealed (with effect on 1 April 2009), on , by section 231(1) of the Taxation (International Taxation, Life Insurance, and Remedial Matters) Act 2009 (2009 No 34).