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HMRC internal manual

Company Taxation Manual

ACT: General: Bonus issue of shares - repayment of share capital


A company may make a bonus issue of redeemable or irredeemable shares at the time of, or following, a repayment of share capital (CTM15420). This may rank as a qualifying distribution under ICTA88/S210.

Where an issue made in such circumstances is of redeemable shares, that issue will not be a distribution by virtue only of ICTA88/S209 (2)(c) (CTM20075) and will therefore be a qualifying distribution.