CFM17410 - MODs: overseas equities – treatment of recipient

Tax treatment of recipient of a MOD from an overseas equity

Companies and individuals

The payment will normally be treated as a trading receipt (taxed under section 5 ITTOIA 2005 for income tax payers) equal to the gross amount of the real overseas dividend if received in the course of a trade carried on the recipient. Otherwise it will be a Case V receipt (or taxed under section 402 ITTOIA 2005 for income tax payers).