Section 614ZC | Treatment of payer of manufactured payment

(1)This section applies where a person has a manufactured payment relationship under which a manufactured payment is paid by or on behalf of the person.

(2)No deduction is allowed in respect of the manufactured payment in calculating any profits or other income of the person for income tax purposes (subject to subsection (3)).

(3)Subsection (2) does not apply in relation to the person so far as the manufactured payment is brought into account under Part 2 of ITTOIA 2005 in calculating the profits of a trade carried on by the person.

(4)But nothing in subsection (3) affects the question whether (apart from that provision) a deduction in calculating the profits of a trade carried on by the person is allowed.