Following the publication of the draft legislation, Karen Hughes and Felicity Cullen QC consider where we are now on corporate distributions
The recent developments on corporate distributions show some similarities to the throw of a boomerang by a lucky amateur. There have been signs of a mis-throw and the threat of a bad landing but the result is what one would have hoped for – broadly a return to the point of origin.
This article summarises and assesses where we now are on corporate distributions ie distributions by companies to UK resident corporate shareholders (which are assumed not to be ‘small companies’).
The recent uncertainty
The recent uncertainty on the taxation of corporate distributions arose as a result of changes in relevant HMRC practice.
As explained below the current exemption for UK-resident companies in relation to dividends and distributions does...
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Following the publication of the draft legislation, Karen Hughes and Felicity Cullen QC consider where we are now on corporate distributions
The recent developments on corporate distributions show some similarities to the throw of a boomerang by a lucky amateur. There have been signs of a mis-throw and the threat of a bad landing but the result is what one would have hoped for – broadly a return to the point of origin.
This article summarises and assesses where we now are on corporate distributions ie distributions by companies to UK resident corporate shareholders (which are assumed not to be ‘small companies’).
The recent uncertainty
The recent uncertainty on the taxation of corporate distributions arose as a result of changes in relevant HMRC practice.
As explained below the current exemption for UK-resident companies in relation to dividends and distributions does...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
