‘The Respondent is the corporate trustee of a tax-exempt United Kingdom pension fund. It held a large portfolio of UK and overseas shares. To generate revenue, it engaged in a practice known as stock lending. This involves a shareholder (the lender) transferring ownership of shares to another party (the borrower) on terms that the borrower will (i) return equivalent shares to the lender at the end of the lending period and (ii) pay an amount to the lender equivalent to the dividends paid on the shares during that period. These payments are known as a “manufactured dividend” (“MD”) if the shares are held in a UK company. If the shares are in a non-UK company, they are known as a “manufactured overseas dividend” (“MOD”).’
UKSC Blog, 27th April 202
Source: ukscblog.com
