Corporation Tax Act 2010

1109 Tax credits for certain recipients of exempt qualifying distributions

(1) This section applies if a company makes a qualifying distribution which is exempt for the purposes of Part 9A of CTA 2009 (company distributions).

(2) If the person receiving the distribution is a UK resident company, that company is entitled to a tax credit equal to one-ninth of the amount or value of the distribution (but see subsection (5)).

(3) If the distribution is, or is treated under any provision of the Tax Acts as, the income of a person (“P”) other than the recipient (“R”), P (not R) is treated as receiving it for the purposes of subsection (2) (and so P (not R) is entitled to a tax credit if P falls within subsection (2)).

(4) Section 1102(2) to (6) (power to obtain certain information from close companies and others) applies for the purposes of this section as it applies for the purposes of section 1101.

(5) This section is subject to the following provisions—

(a) section 808 (no tax credits for borrower under stock lending arrangement),

(b) section 809 (no tax credits for lender under creditor repo or creditor quasi-repo),

(c) section 810 (no tax credits for borrower under debtor repo or debtor quasi-repo), and

(d) section 219(4B) of FA 1994 (no tax credit for distributions in respect of assets in Lloyd’s member’s premium trust fund).