http://www.legislation.gov.uk/ukpga/2010/8/section/59Taxation (International and Other Provisions) Act 2010An Act to restate, with minor changes, certain enactments relating to tax; to make provision for purposes connected with the restatement of enactments by other tax law rewrite Acts; and for connected purposes.texttext/xmlenStatute Law Database2026-05-05Expert Participation2026-03-18 Part 2CHAPTER 2591This section applies for the purposes of section 58.2“Relevant profits”, if the dividend is within subsection (3), means the profits in respect of which the dividend is treated as paid for the purposes of section 931H of CTA 2009 (dividends derived from transactions not designed to reduce tax).3A dividend is within this subsection if—ait is received in an accounting period of the recipient in which the recipient is not a small company for the purposes of Part 9A of CTA 2009 (company distributions: see section 931S of that Act), andbfor the purposes of section 931H of that Act, it is treated as paid in respect of profits other than relevant profits (see subsection (4) of that section).4“Relevant profits”, if the dividend is not within subsection (3) but is paid for a specified period, means—athe distributable profits of that period, plusbif the total dividend exceeds those profits, so much of the distributable profits of preceding periods as is equal to the excess.5“Relevant profits”, if the dividend is not within subsection (3) and is not paid for a specified period, means—athe distributable profits of the last period for which accounts of the company were made up which ended before the dividend became payable, plusbif the total dividend exceeds those profits, so much of the distributable profits of preceding periods as is equal to the excess.6In subsection (4)(b) or (5)(b), the reference to distributable profits of preceding periods does not include—aprofits previously distributed, orbprofits previously treated as relevant profits for the purposes of section 58 or 61 of this Act, section 799 of ICTA or section 506 of the Income and Corporation Taxes Act 1970.7For the purposes of subsection (4)(b) or (5)(b), the profits of the most recent preceding period are to be taken into account first, then the profits of the next most recent preceding period, and so on.8In this section “distributable profits”, in relation to a company, means the profits available for distribution as shown in accounts relating to the company—adrawn up in accordance with the law of the country or territory under whose law the company is incorporated or formed, andbmaking no provision for reserves, bad debts, impairment losses or contingencies other than such as is required to be made under the law of that country or territory.9The reference in subsection (6)(b) to section 799 of ICTA is without prejudice to the generality of paragraph 4(1) of Schedule 9 (references to rewritten provisions include references to superseded provisions).Words in s. 59(6)(b) substituted (retrospectively and with effect in accordance with art. 1(2) of the amending S.I.) by Taxation (International and Other Provisions) Act 2010 (Amendment) Order 2010 (S.I. 2010/2901), arts. 1(1), 4(2)Pt. 2 modified by 1988 c. 1, Sch. 19ABA paras. 26-28 (as inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 34(3) (with Sch. 9 paras. 1-9, 22))Pt. 2 applied by 2010 c. 4, s. 269DL(6) (as inserted (with effect in accordance with Sch. 3 Pt. 3 of the amending Act) by Finance (No. 2) Act 2015 (c. 33), Sch. 3 para. 1)