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Corporation Tax Act 2010

Section 735: Abnormal dividends used for exemptions or reliefs (circumstance A)

2262.This sectionis the first in a sequence of sections in which the sets of circumstances in section 704 of ICTA are laid out and expanded in five separate sections. It is based on sections 704 A and 709(3) of ICTA.

2263.This section is similar to section 686 of ITA. The main change is in subsection (4) wherethepurpose stated differs from those listed in section 686(4) of ITA to cater for the application of the section to companies.

2264.Section 704 A(a) to (c) of ICTA are no longer capable of having any practical effect for corporation tax purposes and are therefore not rewritten.

2265.To avoid confusion, this sequence of sections has been given the same titles as the corresponding provisions of Chapter 1 of Part 13 of ITA. There is accordingly no mention of “circumstance B”, because section 704 B of ICTA was repealed by FA 2008.

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