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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: group and franked investment income

Group and franked investment income received from any company in which the company making the distribution holds not less than 10% of any class of shares, (a ‘related company’), is excluded from the relevant profits of the distributing company. Instead the relevant profits of the related company are included in the distributing company’s relevant profits on a pro-rata basis. Franked investment income other than from a related company is included in the relevant profits of the distributing company.