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The tax and accounting treatment of the repayment of a capital contribution

What is the tax and accounting treatment of the repayment of a contributed surplus from a subsidiary company to a parent company and how should this be treated in the parent company’s books? Jackie Wheaton (BDO) considers the key points.

Capital contributions are not specifically recognised under UK law. Questions can therefore arise as to how these should be treated for tax and accounting purposes: the tax consequences for the recipient and the payer were analysed before in this journal (see ‘Tax on capital contributions’ (Michael Hunter) Tax Journal 11 October 2013).

We have recently been asked to advise on the accounting treatment for a subsidiary company making a repayment of a capital contribution which has previously been paid to it and the resulting tax treatment for the parent company which is receiving the repayment of...

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