Revenue Note for Guidance
This section contains provisions corresponding to those against dividend-stripping (sections 752 and 753) and ensures that measures against “cum div” and “ex div” dealings also apply to non-financial entities.
(1) In determining any tax repayment due to a person who is not a dealer in securities in respect of any trading income, any interest computed in accordance with Schedule 21 and any tax paid on that interest is to be disregarded. In addition, these provisions are carried through for corporation tax purposes.
(2) There is also provision to prevent a company, not engaged in a financial trade, from setting off tax paid on such interest received against any withholding tax deducted under section 238 on any annual payments made by it.
Relevant Date: Finance Act 2021