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Corporate distributions: Where have we landed?

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Earlier this year, HMRC challenged long-established fundamental principles in the corporate distributions world. Fears were later allayed by a Ministerial Statement announcing that the law would be amended to reflect more clearly the position as previously understood. The draft legislation has now been published and it does as promised. Income distributions for tax purposes include dividends from abroad (however the source of funds is characterised under local law), dividends paid out of reserves created on a reduction of capital and any distribution element on a redemption of capital. In addition, the entire consideration payable to a corporate shareholder on a repurchase of shares is brought into the chargeable gains calculation.

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