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Contents

Official guidance
Company Taxation Manual

CTM17500 · Distributions: purchase of own shares

  • CTM17505 · Introduction
  • CTM17507 · Quoted and unquoted companies
  • CTM17510 · Application of the distributions legislation
  • CTM17520 · Shares issued at a premium
  • CTM17530 · Previous bonus issue
  • CTM17540 · Later bonus issue
  • CTM17550 · Repeat bonus issues
  • CTM17560 · Quoted shares
  • CTM17570 · Special treatment for unquoted companies
  • CTM17580 · Return of payment
  • CTM17590 · Scheme or arrangement
  • CTM17600 · Legal costs
  • CTM17630 · From a dealer
  • CTM17640 · Treatment of purchase price in hands of dealer
  • CTM17650 · Redemption of certain preference shares held by a dealer before 2 July 1997
  1. Distributions: purchase of own shares: contents
  2. Distributions: purchase of own shares: quoted shares

CTM17560 | Distributions: purchase of own shares: quoted shares

From HM Revenue & Customs · Company Taxation Manual

Shares which are either:

  • in the official list of the Stock Exchange, or

  • are dealt in on the Alternative Investment Market,

will normally pass through the hands of a market maker in those shares.

The market maker acts as principal. Where such a company purchases its own shares there are two stages in the sale,

  • the shareholder sells to the market maker, and then

  • the market maker sells to the company.

A broker may act as agent of the shareholder and the company. This is not an absolute requirement as a market maker may deal directly with the shareholder and the company.

Exceptionally, the shareholder and the company may not pass the shares through the hands of a market maker. Instead, they may use a broker to execute the transaction. This is an 'agency cross'. In these circumstances the shareholder has sold the shares directly to the company. As a result, the distribution provisions will apply, unless either:

  • the shareholder is a dealer in relation to the shares, see CTM17630, or

  • the transaction is an exempt purchase of own shares within CTA10/S1033.

In most cases the company will use a market maker. The shareholder will sell the shares to the market maker, rather than back to the company, so the shareholder does not receive a distribution. As the market maker is a dealer, a purchase of its own shares by a company from a market maker gives rise to a trading receipt in the market maker’s hands, see CTM17630.

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