263I(1)  The Treasury may by regulations make provision as mentioned in subsection (2) about prescribed cases where a person–

(a)pays or receives an amount (a “manufactured overseas dividend”) which is representative of an overseas dividend on overseas securities where the payment or receipt is required to be made under an arrangement for the transfer of the securities, or

(b)is treated as doing so for any purposes of the Tax Acts.

263I(2)  The regulations may provide for adjusting a relevant amount by reference to a provision which has effect under the law of a territory outside the United Kingdom.

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