[CFM74440] Other tax rules on corporate finance: manufactured payments: payments made on or after 1 January 2014: taxation
This guidance applies to manufactured payments made on or after 1 January 2014. For manufactured payments made before 1 January 2014, see CFM74300.
Tax treatment of manufactured payments
Manufactured interest paid and received by companies is within the loan relationships regime – the rules are explained at CFM46050
The legislation dealing with manufactured payments in other circumstances is contained in ITA07/PT11ZA and CTA10/PT17A. It aims to treat the manufactured payment in the hands of the recipient in broadly the same way as if it were a real dividend or real interest, namely: