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Legislation
Corporation Tax Act 2010

Crossheading Company's entitlement to profits or assets available for distribution: supplementary

  • Section 169 Application and interpretation of sections 170 to 182
  • Section 170 Shares or securities with limited rights
  • Section 171 Shares or securities with temporary rights
  • Section 172 Company A's proportion if shares etc have temporary rights
  • Section 173 Cases in which option arrangements are in place
  • Section 174 Company A's proportion if option arrangements in place
  • Section 174A Certain option arrangements not within section 173
  • Section 174B Certain mortgage arrangements not within section 173
  • Section 175 Cases in which both sections 170 and 172 apply
  • Section 176 Cases in which both sections 170 and 174 apply
  • Section 177 Cases in which both sections 172 and 174 apply
  • Section 178 Cases in which sections 170, 172 and 174 all apply
  • Section 179 Cases in which surrendering or claimant company is non-UK resident
  • Section 180 Company A's proportion if non-UK resident involved
  • Section 181 Assumptions to be applied if non-UK resident company involved
  • Section 182 Assets etc referable to UK trade
  1. Company's entitlement to profits or assets available for distribution: supplementary
  2. Shares or securities with temporary rights

Section 171 | Shares or securities with temporary rights

From legislation.gov.uk

(1)Section 172 applies if, at the relevant time, one or more of the participating equity holders holds, as such, shares or securities—

(a)which have rights within subsection (2), or

(b)in relation to which arrangements within subsection (3) are in place.

(2)The rights within this subsection are distribution rights of such a kind that if—

(a)the profit distribution were to be made, or

(b)the notional winding up were to occur,

at a time after the relevant accounting period, the equity holder's entitlement at that time would be different from the equity holder's entitlement at the relevant time.

(3)The arrangements within this subsection are arrangements of such a kind that if—

(a)effect were to be given to the arrangements, and

(b)the profit distribution were to be made, or the notional winding up were to occur, at a time after the relevant accounting period,

then, as a result of effect being given to the arrangements, the equity holder's entitlement at that time would be different from the equity holder's entitlement at the relevant time.

(4)The references in subsections (2) and (3) to the equity holder's entitlement at a time are references to the proportion to which the equity holder would be beneficially entitled (as the case may be)—

(a)of profits on the profit distribution if it were made at that time, or

(b)of assets on the notional winding up if it occurred at that time.

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