The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:
Distributions received by UK companies are taxable unless they fall within a particular exempt category, regardless of whether they are paid by UK or overseas companies. The relevant rules are contained in CTA 2009, Part 9A. This guidance note outlines the regime and considers what is included within the meaning of distributions for this purpose.
The definition of 'distributions' for the purpose of the corporation tax acts is broad. In overview, it includes the following:
any dividend including capital dividends (this does not include distributions as part of a winding up)
any other distribution out of the assets of the company in respect of shares in the company, whether in cash or otherwise (this does not include the repayment of capital for shares as a distribution)
redeemable share capital or any new security, if not issued for full consideration
interest, or other distribution in respect of non-commercial securities where the consideration given by the company for the loan is more than a reasonable commercial return. Only the excess of interest over a reasonable commercial return is treated as a distribution
interest or other distribution made in respect of 'special securities', which does not fall within the case above relating to non-commercial securities. As above, only the excess of interest over a reasonable commercial return is treated as a distribution
the amount of any benefit received in excess of market value on transfers of assets or liabilities between the company and its members
in certain cases, amounts in respect of bonus issues of shares following a repayment of share capital
**Free trials are only available to individuals based in the UK. We may terminate this trial at any time or decide not to give a trial, for any reason.
Access this article and thousands of others like it free for 7 days with a trial of TolleyGuidance.
Read full article
Already a subscriber? Login
The substantial shareholding exemption (SSE) provides a complete exemption from the liability to corporation tax on the gains generated from qualifying disposals of shares and interests in shares by qualifying companies. Conversely, if losses are generated by the disposal and the SSE conditions are
Summary of capital allowances on carsThe current capital allowance rates applicable to cars are as follows:Pool typeDescription of carRateLegislationMain rate poolNew and unused cars with CO2 emissions over 50g/km but not more than 110g/km (to be reduced to 50g/km and below from April 2021)18%CAA
What is structures and buildings allowance (SBA)?From 29 October 2018, expenditure on constructing a non-residential building or structure, or in certain cases, expenditure on acquiring such a building or structure, qualifies for an SBA. The following note has been updated for the changes announced
Class 1 and Class 1AClass 1 and Class 1A are the categories of NIC that can be charged on expenses reimbursed and benefits provided to employees. These classes are mutually exclusive. A benefit cannot be subject to both Class 1 and Class 1A NIC. Three requirements must be met before Class 1A NIC is
To view our latest tax guidance content, sign in to Tolley Guidance or register for a free trial.