SolvedCTM15940 | Distributions: non-qualifying distributions: nominees
From HM Revenue & Customs · Company Taxation Manual
Where the recipient of a non-qualifying distribution is a nominee, CTA10/S1102 gives HMRC power to ascertain the beneficial owner of the shares. This information will be sought first from the company (or its agent) making the distribution. If the company is unable to supply the information it will be sought from the person in whose name the shares or other member interests are registered.