Explanatory Notes

Corporation Tax Act 2010

2010 CHAPTER 4

3 March 2010

Introduction

Part 23: Company distributions

Chapter 5: Demergers
Section 1091: Advance clearance of distributions

3165.This section allows a company to seek a ruling from the Commissioners for HMRC as to whether a distribution is treated as an exempt distribution. It is based on section 215(1) of ICTA, and is supplemented by section 1093.

3166.The words “the Commissioners for Her Majesty’s Revenue and Customs” have been substituted for the words “the Board” in the source legislation. This gives effect to section 50(1) and (2) of CRCA which require references to the terms in the source legislation to be taken as references to the substituted terms.