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Taxing distributions, naturally!

03 August 2010 / Pete Miller
Issue: 4266 / Categories: Comment & Analysis , Companies
PETE MILLER gives a guided tour of the new legislation relating to distributions


  • UK and non-UK distributions were taxed differently.
  • What is a distribution of a capital nature?
  • Conflict between two new sections.
  • Companies can disregard the new rules for distributions made before 22 June 2010.

The new regime for the taxation of distributions was introduced in CTA 2009 Sch 9A from 1 July 2009. Further changes are proposed for the third Finance Act of 2010 and draft legislation has been published on the HM Treasury website.

The new legislation is intended to clarify the position in respect of distributions ‘of a capital nature’ and to ensure that they are taxed in line with previous expectations. In this article we shall look at whether these aims are achieved.

What went before

Back in the good old days if...

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