CFM17360 - Manufactured overseas dividends (MODs)

Overview and contents

The rules for manufactured overseas dividends (MODs) are in paragraph 4 of ICTA88/Schedule 23A, ITA07/S581 and S582 and ITA07/S922-S925 and regulations made under them. The rules are far more complex than the rules for the other types of manufactured payments. The reasons why are explained at CFM17370.

The rules provide a regime covering both treatment of MODs for tax purposes and setting out a tax deduction regime. Detailed guidance on the operation of the rules is available in guidance notes at www.hmrc.gov.uk/mpgn. The guidance at CFM17365 to CFM17420 summarises the main rules but where more detail is required the guidance notes should be consulted. The guidance notes also include examples of how the rules operate in particular circumstances

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