CTM02050 | Corporation Tax: computation of income: dividends and other distributions made
From HM Revenue & Customs · Company Taxation Manual
Dividends and other distributions are not deductible in computing income.
Most company distributions would not be allowable on basic principles, as distributions of profit rather than expenses of earning it. But some distributions, such as interest treated as a distribution by paragraph E (interest at uncommercial rate) or paragraph F ( on 'special securities' for example interest is results-dependent) might be allowable if this general prohibition did not exist.