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HMRC internal manual

Capital Gains Manual

Depreciatory intra-group dividends: distributable profits

TCGA92/S31 (4)

Distributable profits are defined by TCGA92/S31 (4) as those profits, computed on a commercial basis, which a company may distribute in accordance with company law and any further restrictions in its own articles of association. A proper provision should be made for any tax payable.

Finance Act 2011 introduced a new Targeted Anti-Avoidance Rule for disposals of shares and securities by companies on or after 19 July 2011. See CG48500+.