CTM40125 | Particular bodies: clubs: incorporated as companies - dividends paid

From HM Revenue & Customs · Company Taxation Manual

If a company pays dividends, it will normally be liable to tax as a trading concern. However, if the other conditions in are satisfied, there is likely to be liability only where there is a marked inequality of shareholdings and the dividends are substantial.

Cases of doubt or difficulty, where the tax at stake is substantial, should be submitted to BAI (Technical).