Dividend distribution vouchers from authorised investment
funds are still being issued containing information about the fund’s net liability to corporation
tax.
This seems to be a legacy of the old restriction on repayment of income
tax which was specifically repealed with effect for distributions made at or
after 1.45 p.m. on 22 June 2010 22 June 2010.
Under the current rules the unfranked element in each distribution is
allocated between a UK element and a foreign element (if any). Deemed income tax attributable to the UK
element is creditable with no restriction on repayment. Therefore information about the fund’s net liability to corporation
tax is irrelevant and may serve only to
confuse.
What may be causing the confusion here is that regulation 70 of si 2006/964 requires the net liability to corporation tax figure to be included on a tax voucher even though its no longer relevant information. As far as I can see there's nothing in the regs at all to require that the foreign income is disclosed to corporate investors. I suspect that regulation 70 just hasn't been updated for the 2010 changes.
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