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HMRC internal manual

Capital Gains Manual

Capital distributions: introduction


A capital distribution is any distribution from a company which is not treated as income for income tax purposes. Most distributions, for example, dividend payments, will be income distributions. The capital distributions you are most likely to see in practice are distributions in the course of a winding-up. The sale of provisional letters of allotment in a rights issue is also treated as a capital distribution. Certain distributions made in the course of a demerger are deemed not to be capital distributions.

The receipt of a capital distribution is treated as a disposal of an interest in the underlying shares. The normal computational rules apply unless the distribution is small compared with the value of the shareholding. For advice on small capital distributions see CG57835+.