Commentary

D4.907 Examples of holdings qualifying for underlying tax relief

Corporate tax
Corporate tax | Commentary

D4.907 Examples of holdings qualifying for underlying tax relief

Corporate tax | Commentary

D4.907 Examples of holdings qualifying for underlying tax relief

FA 2009 introduced the exempt distribution regime which broadly provides that most dividends received by a UK company on or after 1 July 2009 (from the UK or overseas) will be exempt from corporation tax (see Division D5.1). The provisions discussed in this article apply to overseas dividends received on or after 1 July 2009 that are not exempt and all other overseas dividends received before 1 July 2009.

For the purpose of the following examples it is assumed that the shares mentioned are voting shares which entitle the holder to the relevant percentage of the voting power/ordinary share capital in the company. It is also assumed that each of the companies has only one class of shares.

Example 1

Shares held

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