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HMRC internal manual

Company Taxation Manual

HM Revenue & Customs
, see all updates

Distributions: non-qualifying distributions: receipt of distribution

The assessment of a non-qualifying distribution received by an individual is dealt with in SAIM5050 onwards.

Non qualifying distributions received by a company resident in the UK are not liable to tax, nor are they franked investment income.


  • a company receives a non-qualifying distribution, and
  • it distributes the non-qualifying distribution in turn to its shareholders, this distribution is also treated as a non-qualifying distribution