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HMRC internal manual

Company Taxation Manual

Corporation Tax: computation of income: dividends and other distributions made

CTA09/S1305(1) (formerly ICTA88/S337A (1)(a))

Dividends and other distributions are not deductible in computing income.

Most distributions would not have been allowable on ordinary IT principles anyway. But some distributions, such as interest treated as a distribution by CTA10/S1000(1), paragraph F, the ’special securities’ provision formerly within ICTA88/S209 (2)(e), might be allowable if this general prohibition did not exist.