Commentary

D6.606 Buy-back of share capital—distribution treatment

Corporate tax
Corporate tax | Commentary

D6.606 Buy-back of share capital—distribution treatment

Corporate tax | Commentary

D6.606 Buy-back of share capital—distribution treatment

A purchase of shares by a company will be treated as a chargeable distribution to the extent that it exceeds the amount originally subscribed for the shares (ie to the extent that it represents a repayment of share capital (D6.607))1 unless:

  1.  

    (a)     it meets the necessary conditions to be treated as a capital payment (D6.610)

  2.  

    (b)     it is in exchange for new consideration2; or

  3.  

    (c)     (for transfers before 17 July 2012) the recipient is a company resident in the UK of which the company making the distribution is a 51% subsidiary or both the

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