FORTHCOMING CHANGE: At Tax Update 2026, HMRC published a consultation on 'Modernising the distributions framework'. The consultation includes a range of proposals aimed at reducing opportunities for income tax payers to extract value from companies in the form of capital rather than income, including: • preventing the implementation of new holding company structures which facilitate the extraction of value as capital. Currently, the insertion of a new holding company above an existing group holding company results in the shareholders holding ‘good tax capital’ in the new holding company equal to the market value of the old holding company’s shares. A reduction in capital of the new holding company therefore represents a repayment of capital rather than an income distribution. The consultation proposes that share buybacks and other returns of capital ‘reflect a “frozen” amount of capital on the shares in any future holding company at the amount subscribed on the original investment, matching the CGT deferment of the original base cost’ • relaxing the tax conditions to effect a direct or indirect statutory demerger • aligning

FORTHCOMING CHANGE: At Tax Update 2026, HMRC published a consultation on 'Modernising the distributions framework'. The consultation includes a range of proposals aimed at reducing opportunities for income tax payers to extract value from companies in the form of capital rather than income, including: • preventing the implementation of new holding company structures which facilitate the extraction of value as capital. Currently, the insertion of a new holding company above an existing group holding company results in the shareholders holding ‘good tax capital’ in the new holding company equal to the market value of the old holding company’s shares. A reduction in capital of the new holding company therefore represents a repayment of capital rather than an income distribution. The consultation proposes that share buybacks and other returns of capital ‘reflect a “frozen” amount of capital on the shares in any future holding company at the amount subscribed on the original investment, matching the CGT deferment of the original base cost’ • relaxing the tax conditions to effect a direct or indirect statutory demerger

Distribution grid connection agreements Distribution-level connection agreements are most commonly used to connect a 'distributed' or 'embedded' generator to a distribution network (so called because it is connected to a distribution system); most external lawyers will encounter a distribution connection agreement in this context. Where you are dealing with a generation project being newly built, in the first instance you will generally see a ‘connection offer’ being entered into with the relevant licensed electricity distribution network operator (DNO), before the connection agreement. This is because a connection offer by the DNO (and acceptance by the generator) will deal with locking in a right to an ongoing connection once the relevant project has been built and will also deal (to a varying degree) with the construction of the connection between the new generation project and the distribution network, ie the connection works enabling the generation project to connect to the grid. In turn, the connection agreement (as dealt with in this Checklist) will deal with the right of the generator for the plant to remain energised

The network over which signals and messages are transmitted, eg a telephony or cable TV network, or a terrestrial or satellite TV broadcast network.

Distribution of profits describes the way in which a business or other undertaking allocates its surplus income to owners, members or participants, rather than retaining it in the entity. In company law, it most commonly refers to the payment of dividends or other distributions to shareholders out of distributable profits, subject to capital maintenance rules in the Companies Act 2006 (England and Wales, Scotland, Northern Ireland) and the Companies Act 2014 (Ireland). The term is also used for profit‑sharing in partnerships and LLPs, where allocation is governed primarily by the partnership or LLP agreement and relevant partnership or LLP legislation, rather than capital maintenance rules. In private equity and investment funds, “distribution of profits” can describe the waterfall or carried interest mechanism. Across the UK and Ireland, the concept is broadly consistent: profits may only be distributed in accordance with statute, the entity’s constitutional documents and any contractual arrangements. Directors and partners must consider fiduciary duties, solvency tests, tax consequences and potential creditor interests when authorising or implementing a distribution of profits.

Property analysis: The court confirmed that the proper approach to the distribution of rental payments from land between co-owners is to determine the common intention of the parties.

Restructuring & Insolvency analysis: Mr Justice Rajah has approved a distribution plan proposed by the Special Administrators of an investment bank, under the Investment Bank Special Administration (England and Wales) Rules 2011 (‘IBSA Rules’) which, for the first time, was not in line with the rights of the bank’s clients. As the bank’s records were unreliable, the Special Administrators carried out a reconciliation exercise to determine the assets and money which belonged to each client for the purpose of the distribution plan. Following an adjournment for a review of the reconciliation exercise by independent counsel, it was held that it was fair and reasonable for the distribution plan to be based on the reconciliation exercise. The court also approved a costs reserve in respect of incurred and future costs; however, a proposal to maintain a further sum for a potential litigation reserve was refused as a distribution plan including this proposal was not fair and reasonable. Written by Dale Timson, barrister at Enterprise Chambers.

An intermediary node in an NGA (next generation access) network from where one or several fibre cables coming from the Metropolitan Point of Presence (MPoP) (the feeder segment) are split and distributed to connect to end-users' premises (the terminating or drop segment). A distribution point generally serves several buildings or houses. It can be located either at the base of a building (in case of multi-dwelling units), or in the street. A distribution point hosts a distribution frame mutualising the drop cables, and possibly un-powered equipment such as optical splitters.

A performer has the right to prevent the distribution of the performer's work.

This is a mechanism which is usually set out in the partnership'>limited partnership agreement of a fund, which governs how cash is returned to investors (the limited partners), the private equity house (via the general partner and then the manager or adviser) and the investment professionals who work for the manager. It sets out the order in which cash is distributed and may ensure different types of investors have priority of payment compared to others who have made investments in the same fund.

A company has an implied power to distribute its profits to its members, unless its articles of association provide otherwise. A dividend is one type of distribution that may be made by a company to its members. In fact, dividends are the most common type of distribution made by a company. However, a company is under no legal obligation to pay a dividend, unless the rights attaching to its shares specify that it must. The ordinary meaning of 'dividend' is a share of profits, whether at a fixed rate or otherwise, allocated to the holders of shares in a company. It is used in relation to payments made to shareholders as shareholders and not, eg, by way of remuneration for services. A dividend is typically satisfied by a direct payment of cash or by a transfer of non-cash assets (being any property or interest in property other than cash; in the Companies Act 2006, 'cash' is expressed to include foreign currency). A dividend satisfied by a transfer of non-cash assets is often known as a dividend in kind or a dividend

A distributor is an independent contractor who buys goods on their own account from an exporter or supplier and resells the goods to customers in their own territory.