Capital treatment for purchase of own shares

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

Capital treatment for purchase of own shares

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
imgtext

This guidance note sets out the tax effect of the ‘capital treatment’ for a relevant shareholder on the purchase of own shares by a company. See the Purchase of own shares ― overview guidance note for a summary of this area.

The tax treatment for the shareholders in a company on a purchase of own shares will fall into one of two categories ― either the ‘income treatment’ or the ‘capital treatment’. For shareholders who are individuals, the income treatment will apply by default to the repurchase. See the Income treatment for purchase of own shares guidance note for details.

For a corporate shareholder, the default treatment is broadly similar with the corporate shareholder treated as receiving an income distribution for corporation tax purposes as well as disposing of its shares for corporation tax on chargeable gains purposes. If this default treatment applies, it is possible that the distribution will fall within one of the dividend exemptions and, as a result, the entire amount received on the buyback is brought into tax as

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™
Powered by Tolley+
  • 23 Jun 2026 14:20

Popular Articles

Associated companies ― from 1 April 2023

Associated companies ― from 1 April 2023Implications of associated companiesFrom 1 April 2023, the rate of corporation tax that a company is subject to depends on the level of its augmented profits. The rate of tax is based on a comparison of the company’s augmented profits against the corporation

22 Mar 2021 10:21 | Produced by Tolley Read more Read more

First year allowances

First year allowancesFirst year allowances (FYAs) are available on the following items:•first-year relief on qualifying new main rate plant and machinery (at 100%, which is described by HMRC as ‘full expensing’) and special rate assets (at 50%) from 1 April 2023 (companies only). These FYAs were

14 Jul 2020 11:41 | Produced by Tolley Read more Read more

Parking provision and expenses

Parking provision and expensesCar parking facilities at or near to the employee’s workplaceThere is an exemption from tax and NIC where an employer provides parking, or pays for or reimburses an employee for the costs associated with car parking at or near the place of work; there are no reporting

14 Jul 2020 11:09 | Produced by Tolley Read more Read more