Commentary

D5.155 Non-small company distribution exemption—portfolio holdings

Corporate tax
Corporate tax | Commentary

D5.155 Non-small company distribution exemption—portfolio holdings

Corporate tax | Commentary

D5.155 Non-small company distribution exemption—portfolio holdings

Distributions will be exempt if they fall within one or more of the five exempt classes as summarised in D5.152, one of these is where the distribution is in respect of portfolio holdings1.

A distribution falls into this exempt class if the recipient2:

  1.  

    •     holds less than 10% of the issued share capital of the payer

  2.  

    •     is entitled to less than 10% of the profits available for distribution to holders of the issued share capital of the company making the distribution, and

  3.  

    •     would be entitled to less than 10% of the paying company's assets on a winding up available for distribution to holders of the issued share capital of the company making the distribution

Where the payer has issued shares of more than one class, the reference above to

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