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HMRC internal manual

Company Taxation Manual

Distributions: general: companies not carrying on a business

CTA10/S1071 applies where a company has never carried on a trade or a business of holding investments.

The distributions legislation applies to such a company only in respect of distributions that are made out of:

  • profits that are charged to CT (less the CT on those profits),


  • franked investment income,

This provision is important in relation to distributions of unincorporated associations (see CTM15540) which are not carrying on a business of mutual trading (see BIM24000 onwards).