SolvedCTM81080 | Groups & consortia: groups - entitlement to profits or assets available for distribution: varying and limited rights - effect
From HM Revenue & Customs · Company Taxation Manual
CTA10/S171 and CTA10/S175
There are four different possible determinations of profits and of assets in a winding-up where CTM81060 and CTM81065 apply as well as CTM81070 and CTM81075. The four possible combinations of accounting periods and treatment of rights are:
rights of a different accounting period, treating limited rights as waived,
rights of the current accounting period, treating limited rights as waived,
rights of a different accounting period (not treating limited rights as waived),
rights of the current accounting period (not treating limited rights as waived).
| Rights of current accounting period | Rights of a different accounting period |
|---|---|
| Limited rights treated as waived | Limited rights treated as waived |
| No special treatment of rights | No special treatment of rights |
The lowest percentage entitlement to profits arising from these combinations is taken for the purposes of CTA10/S165.
The lowest percentage entitlement to assets in a winding-up is taken for the purposes of CTA10/S166.