HMRC internal manual

Business Income Manual

BIM24550 - Meaning of trade: mutual trading and members clubs: distributions: introduction and layout of guidance: contents

It follows from first principles that distributions out of the surpluses from mutual trading to members by a continuing mutual concern (corporate or non-corporate) are trading receipts where the member who receives them does so because of the trade they carry on - see BIM24555. In addition there are two statutory provisions:

S1070 Corporation Tax Act 2010

There is guidance at BIM24565.

S104 Income Tax (Trading and Other Income) Act 2005, S101 Corporation Tax Act 2009

There is detailed guidance at BIM24600 onwards.

The following guidance covers: