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Contents

Official guidance
Company Taxation Manual

CTM81000 · Groups & consortia: groups - entitlement to profits or assets available for distribution

  • CTM81005 · Introduction
  • CTM81010 · Definitions of terminology
  • CTM81015 · Convertible shares and securities
  • CTM81020 · Business results dependency test
  • CTM81025 · Equity holders - special rule
  • CTM81030 · Equity holders - banks
  • CTM81035 · Equity holders - subsidiary profits available to
  • CTM81040 · Equity holders - subsidiary assets available to
  • CTM81045 · Equity holders - percentage of profits available to
  • CTM81050 · Equity holders - notional winding-up
  • CTM81055 · Returned amounts
  • CTM81060 · Limited rights
  • CTM81065 · Effect of limitation of rights
  • CTM81070 · Varying rights for different accounting periods
  • CTM81075 · Varying rights for different accounting periods - effect
  • CTM81080 · Varying and limited rights - effect
  • CTM81085 · Entitlement different - effect
  • CTM81090 · Option arrangements
  • CTM81095 · Effective rights
  • CTM81100 · Option rights exist
  • CTM81105 · Option, limited & varying rights
  • CTM81110 · Option, limited & varying rights: referable to UK trade of non-resident company
  • CTM81115 · Option arrangements - Board's policy
  • CTM81120 · Examples - background
  • CTM81121 · Example 1 - basic rule
  • CTM81122 · Example 2 - limited rights
  • CTM81123 · Example 3 - varying rights for different accounting periods
  • CTM81124 · Example 4 - option rights
  1. Groups & consortia: groups - entitlement to profits or assets available for distribution: contents
  2. Groups & consortia: groups - entitlement to profits or assets available for distribution: option, limited & varying rights

CTM81105 | Groups & consortia: groups - entitlement to profits or assets available for distribution: option, limited & varying rights

From HM Revenue & Customs · Company Taxation Manual

CTA10/S176 to S178

Where there are option rights (CTM81085 to CTM81100) and also:

  • shares with limited rights (CTM81060 and CTM81065), and/or

  • shares with varying rights (CTM81070 and CTM81075),there are eight different possible calculations of entitlements to profits and of assets in a winding-up as below.

    The eight possible combinations are:

  1. option rights treated as effective, rights of a different accounting period, treating limited rights as waived,

  2. option rights treated as effective, rights of the current accounting period, treating limited rights as waived,

  3. option rights treated as effective, rights of a different accounting period, no special treatment of limited rights,

  4. option rights treated as effective, rights of the current accounting period, no special treatment of limited rights,

  5. option rights ignored, rights of a different accounting period, treating limited rights as waived,

  6. option rights ignored, rights of the current accounting period, treating limited rights as waived,

  7. option rights ignored, rights of a different accounting period, no special treatment of limited rights,

  8. option rights ignored, rights of the current accounting period, no special treatment of limited rights.

Rights of current accounting periodRights of a different accounting period
Option rights effective, Limited rights waivedOption rights effective, Limited rights waived
Option rights effective, No special treatment of limited rightsOption rights effective, No special treatment of limited rights
Option rights ignored, Limited rights waivedOption rights ignored, Limited rights waived
Option rights ignored, No special treatment of limited rightsOption rights ignored, No special treatment of limited rights

The lowest percentage is taken as the percentage to which the parent company is entitled.

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