Commentary

D6.607 Distribution treatment—Repayment of share capital

Corporate tax
Corporate tax | Commentary

D6.607 Distribution treatment—Repayment of share capital

Corporate tax | Commentary

D6.607 Distribution treatment—Repayment of share capital

A payment is treated as a repayment of share capital if it is1:

  1.  

    (a)     made more than ten years after the latest issue of shares of that class; and

  2.  

    (b)     not in respect of redeemable shares; and

  3.  

    (c)     made by either a:

    1.  

      (1)     quoted company whose shares (other than preference shares or debentures) are listed on the Stock Exchange; or

    2.  

      (2)     company which is not under the control of five or fewer persons; or

    3.  

      (3)     company which is controlled by a company within (1) or (2).

When establishing the amount of the share capital repaid

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