CTM21150 | ACT: FID: general: election: specific rules
From HM Revenue & Customs · Company Taxation Manual
Specific rules existed where the recipient was:
an individual,
a personal representative of a deceased person,
a trustee of an accumulation or discretionary trust.
These rules were modelled on the stock dividend provisions of ICTA88/S249.
A FID was a qualifying distribution and accordingly taxable under ICTA88/S20 in the hands of a non-corporate recipient. It did not carry a tax credit.
For a corporate recipient an FID received was not franked investment income since it did not carry a tax credit (ICTA88/S238 (1)). However the FID received was available to frank FID paid.
A FID received was not chargeable to CT (ICTA88/S208).