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Contents

Official guidance
Company Taxation Manual

CTM20050 · ACT: General

  • CTM20055 · Distributions
  • CTM20060 · Franked payments
  • CTM20065 · Rate of ACT
  • CTM20070 · Qualifying and non-qualifying distributions
  • CTM20075 · Bonus issue of securities or redeemable shares
  • CTM20080 · Bonus issue of shares - repayment of share capital
  • CTM20085 · Repayment of shares and securities
  • CTM20090 · Ultra vires dividends
  • CTM20095 · Notes on company law aspects of dividends
  1. ACT: General: Contents
  2. ACT: General: Repayment of shares and securities

CTM20085 | ACT: General: Repayment of shares and securities

From HM Revenue & Customs · Company Taxation Manual

ICTA88/S211 and ICTA88/209 (2)(e)

Even though a bonus issue of redeemable shares was a non-qualifying distribution on issue, the later repayment of the shares may be a qualifying distribution under ICTA88/S211, CTM15400.

Similarly where a bonus issue of securities, which was a non-qualifying distribution on issue, is repaid, that repayment may be a qualifying distribution under S209 (2)(e), CTM15500.

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