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HMRC internal manual

Company Taxation Manual

ACT: FID: general: anti-streaming provisions

A FID did not carry a tax credit. Because of this, some shareholders (for example, an exempt body to whom any tax credit would be payable) would prefer to receive an ordinary dividend rather than an FID.

If a shareholder could choose to replace an FID with an ordinary dividend the cost to the Exchequer would have increased.

The legislation effectively prevented shareholders from being able to decide whether to receive an FID or an ordinary dividend (streaming). It did this by imposing various conditions that had to be satisfied if a company was to be able to elect for a particular dividend to be an FID. These conditions are set out in CTM21110.