CTM40975 | Particular Trades: mutual concerns: distributions
From HM Revenue & Customs · Company Taxation Manual
A company which carries on mutual business, that is
mutual trading,
mutual insurance, or
other mutual business
will be treated as making a distribution within only so far as it is a relevant distribution made out of profits brought into the charge to Corporation Tax, or out of franked investment income.
A relevant distribution means a distribution made to a person who participates in the mutual activities of the business and which derives from those activities. See onwards.
ACT is not payable by a company on distributions made on or after 6 April 1999.
BAI (Technical) will advise if necessary.