Section 931G — Corporation Tax Act 2009: Distributions in respect of portfolio holdings

Distributions in respect of portfolio holdings 931G 1 A dividend or other distribution falls into an exempt class if the recipient—

a holds less than 10% of the issued share capital of the payer, b is entitled to less than 10% of the profits available for distribution to holders of the issued share capital of the payer, and c would be entitled on a winding up to less than 10% of the assets of the company available for distribution to holders of the issued share capital of the payer.

2 Where the payer has more than one class of share, references in subsection (1) to the issued share capital of the payer are to issued share capital of the same class as the share in respect of which the distribution is made.

3 For the purposes of this section shares are not of the same class if the amounts paid up on them (otherwise than by way of premium) are different.