CFM17385 - MODs: MOD paid to overseas recipient

MOD paid to overseas recipient without deduction of tax

Regulation 5 provides a number of circumstances when AUKI/AUKCAs can pay without deducting tax under ITA07/S922. The purpose is to allow gross payment where a MOD is paid to or for the benefit of a person beneficially entitled to it who is not a UK recipient. The rule covers payments by a dividend manufacturer direct to overseas recipients and payments along a chain of AUKI/AUKCAs where the initial payment is by an AUKI and the final payment goes abroad.