Commentary

D7.726 Sale of foreign dividend coupons

Corporate tax
Corporate tax | Commentary

D7.726 Sale of foreign dividend coupons

Corporate tax | Commentary

D7.726 Sale of foreign dividend coupons

Income treated as arising from the following transactions in dividend coupons that represent foreign holdings is charged to corporation tax1.

Dividend coupons are coupons for dividends in respect of foreign holdings and include warrants and bills of exchange2. Foreign holdings are shares outside the UK that are issued by or on behalf of a non-UK resident body of persons3.

Note a dividend coupon is only taxable under these provisions if the associated dividend would not be exempt under the exempt distribution regime (see Division D5.1) had it been paid to the holder of the shares4.

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