419. Taxation of non-UK resident recipients of certain distributions.

Where a person's income for a tax year includes a distribution of a company, and the person is non-UK resident1, that person is treated as having paid income tax at the dividend ordinary rate2 on the amount or value of the distribution3.

Where a person is liable to income tax on a CD distribution4, the person's liability to income tax on a subsequent non-CD distribution is reduced if the non-CD distribution consists of a repayment of the share capital, or the principal of the security, which constituted the CD distribution