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:

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