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HMRC internal manual

Company Taxation Manual

Particular topics: company dissolution: company not dissolved


If  two years have passed since the making of a distribution and the company

  • has not been dissolved, or
  • has failed to satisfy the first condition mentioned at CTM36220

then it is treated as if the relief from CT distribution treatment given by CTA10/S1030A had never applied.


If a company is treated as having distributed assets in the course of a winding-up under ESCC16, and some event gives an officer reason to believe the company will not be struck off or that one or other of the conditions in CTM36220 will not be satisfied, the circumstances should be reported to CTIS (Technical)