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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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Particular topics: dividend-stripping: exempt bodies: minimum shareholding 10%

ICTA88/S235 applies only when the exempt body holds not less than 10% of the shares in respect of which the distribution is made including any associated holdings. Holdings are ‘associated’ if they are acquired ‘by persons acting in concert’ or ‘under arrangements made by any person’.