Steve Edge and Sara Luder of Slaughter and May consider some of the tax issues that arise when a listed company wants to return surplus funds to its shareholders
There has been a gradual revival in transactions that seek to return funds to shareholders as a capital rather than an income receipt for UK tax purposes.
Before the abolition of ACT in 1999 it was often attractive to a company to structure a return of value as a repayment of capital rather than an income distribution as it avoided the requirement to account for ACT (though see the comments below about the one-time popularity of special dividends). Since 1999 for corporation tax purposes there is now in practice no distinction for the company between a...
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Steve Edge and Sara Luder of Slaughter and May consider some of the tax issues that arise when a listed company wants to return surplus funds to its shareholders
There has been a gradual revival in transactions that seek to return funds to shareholders as a capital rather than an income receipt for UK tax purposes.
Before the abolition of ACT in 1999 it was often attractive to a company to structure a return of value as a repayment of capital rather than an income distribution as it avoided the requirement to account for ACT (though see the comments below about the one-time popularity of special dividends). Since 1999 for corporation tax purposes there is now in practice no distinction for the company between a...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
