Commentary

D1.223 Non-trading companies, etc

Corporate tax
Corporate tax | Commentary

D1.223 Non-trading companies, etc

Corporate tax | Commentary

D1.223 Non-trading companies, etc

Where a company has never carried on a trade or business of holding investments, and is not established for purposes which include such activities, the provisions of the corporation tax acts relating to distributions will apply to its distributions only to the extent to which they are made out of the company's profits brought into the charge to corporation tax or out of exempt ABGH distribution income (franked investment income prior to 6 April 2016)1. The term 'AGBH distribution' was introduced as part of the changes introduced to dividend taxation from 6 April 2016 which included

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