Commentary

E1.415 Dividends etc from UK resident companies—relief from tax

Personal and employment tax

E1.415 Dividends etc from UK resident companies—relief from tax

E1.415 Dividends etc from UK resident companies—relief from tax

For 2016/17 onwards, tax is treated as paid on distributions received in the following circumstances.

Distributions received by non-UK residents

A distribution from a company received by a non-UK resident person is treated as having already suffered tax at the dividend ordinary rate. Such income tax is not, however, repayable1.

A distribution falling within these rules is 'non-qualifying income' for the purpose of ITA 2007, s 1025 (meaning of 'modified net income') in the calculation of income tax liability2.

For commentary on the UK tax liability of non-residents, see E6.125.

Repayment of earlier distribution of shares or securities

Relief is available where a person receives a distribution (a 'non-CD distribution') which is a repayment of share capital or principal received through an earlier 'CD distribution'3. A CD distribution is a distribution consisting of redeemable share capital or securities issued as a bonus in

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial