This guidance applies to manufactured payments made before 1 January 2014, when the tax rules were simplified. For manufactured payments made on or after 1 January 2014, see CFM74430.

The deduction of tax regime for manufactured overseas dividends (MODs)

The tax deduction regime for MODs has three main aims.

First, to put the UK recipient in the same position (so far as possible) as if he received the real overseas dividend of which the MOD is representative;

Second, to ensure that a UK recipient of a MOD should not be able to claim DTR in circumstances where no overseas tax has been suffered.

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