This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Company Taxation Manual

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