Dividends and distributions

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Practice notes
VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes
Why have a tax covenant?It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a...
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Dividends and distributions content

Practice notes
How are individuals taxed on distributions received from companies?This Practice Note explains the rules that apply to distributions made to UK...
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21st Sep
Practice notes
Transactions in securities—clearances and administrationThis Practice Note covers the:•clearance procedure, and•administrative rules (enquiries,...
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19th Aug
Q&As
What is franked investment income (FII) and does it still matter?It is in the context of the old advance corporation tax regime that FII is most often...
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16th Aug
Practice notes
How are small companies taxed on distributions received?Any dividend or other distribution of a company is subject to corporation tax unless that...
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15th Aug
Practice notes
Transactions in securitiesThis Practice Note covers the transactions in securities (TiS) rules relating to the avoidance of both income tax and...
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15th Aug
Practice notes
Tax—types of distribution—dividendsAs further explained in Practice Note: Scope of distributions for tax purposes, distributions can be divided into...
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15th Aug
Practice notes
Distribution exemption—non-redeemable ordinary sharesA non-small company is subject to corporation tax on a distribution received unless, amongst...
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15th Aug
Practice notes
How are non-small companies taxed on distributions received?Any dividend or other distribution of a company received by a company within the charge to...
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15th Aug
Practice notes
Tax issues on a scrip or stock dividendWhat is a scrip dividend and why do companies make them?A scrip dividend, also referred to as a scrip or stock...
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15th Aug
Practice notes
How are individuals taxed on distributions received from non-UK resident companies prior to 6 April 2016? [Archived]ARCHIVED: This Practice Note has...
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15th Aug
Practice notes
Types of distribution—bonus issuesAs further explained in Scope of distributions for tax purposes, distributions can be divided into four...
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15th Aug
Practice notes
Distribution exemption—controlled companies on or after 1 January 2013A non-small company is subject to corporation tax on a distribution received...
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15th Aug
Practice notes
Distribution exemption—portfolio holdingsA non-small company is subject to corporation tax on a distribution received unless, amongst certain other...
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15th Aug
Practice notes
Distribution exemption—transactions not designed to reduce taxA non-small company is subject to corporation tax on a distribution received unless,...
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15th Aug
Practice notes
Scope of distributions for tax purposesThe most common type of distribution is a dividend paid in cash by a company to its shareholders, ie a direct...
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15th Aug
Practice notes
Distribution key concepts—repayment of capitalAlongside the concept of new consideration, which is further explained in Distribution key concepts—new...
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15th Aug
Practice notes
Distribution exemption—controlled companies before 1 January 2013 [Archived]ARCHIVED: This archived Practice Note sets out the conditions that must be...
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15th Aug
Practice notes
Distribution exemption—targeted anti-avoidanceThere are eight anti-avoidance provisions which prevent the application of one or more of the exempt...
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15th Aug
Practice notes
Distribution exemption—general anti-avoidanceThere are eight anti-avoidance provisions which prevent the application of one or more of the exempt...
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15th Aug

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