Corporation Tax Act 2010 (c. 4)

Part 23 U.K. Company distributions

Chapter 2 U.K. Matters which are distributions

Distributions in respect of non-commercial securities U.K.

1005 Meaning of “non-commercial securities” U.K.

For the purposes of paragraph E in section 1000(1) securities of a company are non-commercial securities if the consideration given by the company under the securities for the use of the principal secured by them represents more than a reasonable commercial return for the use of that principal.