D4.942 Shares treated as loan relationshipsFA 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.Under the loan relationship provisions1, certain shares are recharacterised as debt where specified conditions are met. Dividends payable on or after 16 March 2005 in respect
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.
Under the loan relationship provisions1, certain shares are recharacterised as debt where specified conditions are met. Dividends payable on or after 16 March 2005 in respect
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