81.Part 9A aligns the treatment of UK and foreign distributions and provides that the great majority will not be taxable.
82.Exemption is available to all sizes of company and for distributions arising from any size of shareholding.
83.In recognition of the fiscal risks associated with distribution exemption there are anti-avoidance rules to prevent abuse whereby profits that would otherwise have been subject to tax are returned as a tax exempt distribution.
Text created by the government department responsible for the subject matter of the Act to explain what the Act sets out to achieve and to make the Act accessible to readers who are not legally qualified. Explanatory Notes were introduced in 1999 and accompany all Public Acts except Appropriation, Consolidated Fund, Finance and Consolidation Acts.
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