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HMRC internal manual

Company Taxation Manual

ACT: FID: general: election: specific rules

Specific rules existed where the recipient was:

  • an individual,
  • a personal representative of a deceased person,
  • a trustee of an accumulation or discretionary trust.

These rules were modelled on the stock dividend provisions of ICTA88/S249.

A FID was a qualifying distribution and accordingly taxable under ICTA88/S20 in the hands of a non-corporate recipient. It did not carry a tax credit.

For a corporate recipient an FID received was not franked investment income since it did not carry a tax credit (ICTA88/S238 (1)). However the FID received was available to frank FID paid.

A FID received was not chargeable to CT (ICTA88/S208).