Commentary

D4.942 Shares treated as loan relationships

Corporate tax
Corporate tax | Commentary

D4.942 Shares treated as loan relationships

Corporate tax | Commentary

D4.942 Shares treated as loan relationships

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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