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HMRC internal manual

Capital Gains Manual

Recovery of CT from shareholders: assessment under TCGA92 S189: amount


The amount of Corporation Tax to which a shareholder connected with the company may be charged cannot exceed the lower of

  • the value of the capital distribution the shareholder received or has become entitled to receive
  • the proportion of the Corporation Tax payable on the chargeable gain which is the same as the proportion the shareholder received of the capital distribution made by the company.