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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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ACT: General: Repayment of shares and securities

ICTA88/S211 & ICTA88/209 (2)(e)

Even though a bonus issue of redeemable shares was a non-qualifying distribution on issue, the later repayment of the shares may be a qualifying distribution under Section 211 (CTM15400).

Similarly where a bonus issue of securities, which was a non-qualifying distribution on issue, is repaid, that repayment may be a qualifying distribution under Section 209 (2)(e) (CTM15500).