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HMRC internal manual

Company Taxation Manual

Distributions: non-qualifying distributions: nominees


Where the recipient of a non-qualifying distribution is a nominee, CTA10/S1102 gives HMRC power to ascertain the beneficial owner of the shares. This information will be sought first from the company (or its agent) making the distribution. If the company is unable to supply the information it will be sought from the person in whose name the shares etc are registered.