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HMRC internal manual

Company Taxation Manual

Particular topics: dividend-stripping: exempt bodies: repayments of capital

ICTA88/S235 does not apply to payments treated as distributions by virtue of ICTA88/S209 (3), ICTA88/S210 or ICTA88/S211, which may instead be caught by ICTA88/S237, see CTM36775 and CTM36780. See also ICTA88/S731 - S735 regarding bond washing by exempt bodies (IM4385 onwards).