CTM15950 | Distributions: non-qualifying distributions: receipt of distribution
From HM Revenue & Customs · Company Taxation Manual
The assessment of a non-qualifying distribution received by an individual is dealt with in onwards.
Non-qualifying distributions received by a company resident in the UK are not liable to tax, nor are they franked investment income.
Where
a company receives a non-qualifying distribution, and
it distributes the non-qualifying distribution in turn to its shareholders,
this distribution is also treated as a non-qualifying distribution.