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HMRC internal manual

Company Taxation Manual

Particular topics: dividend-stripping: exempt bodies: reference to Head Office

Any case that presents particular difficulties may be submitted to Business Tax, Special Investigations Section 2 (SIS2), 22 Kingsway, London WC2B 6NR, for advice. Where the distribution received by the exempt shareholder substantially exceeds a normal return as defined at ICTA88/S709 (4) - (6) the case should always be referred to SIS2 before any action under ICTA88/S235 is taken as SIS2 may wish to invoke ICTA88/S703 to deny repayment of the tax credit on any part of the distribution which is not caught by ICTA88/S235. Any request for comments on the possible application of ICTA88/S235 to a proposed dividend should also be referred to SIS2.