Related Commentary  

9(1)  In the circumstances prescribed by paragraph (2) and subject to paragraph (4), a person who is an overseas dividend manufacturer in any chargeable period shall be entitled to set off the amounts specified in paragraph (1A) against the sums specified in paragraph (1B). This is subject to regulation 9ZA.

9(1A)  The amounts specified in this paragraph are–

(a)amounts of overseas tax in respect of overseas dividends received by the overseas dividend manufacturer in the chargeable period otherwise than as foreign permanent establishment receipts;

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