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HMRC internal manual

Company Taxation Manual

Particular topics: dividend-stripping: distributions: abnormal return: reference to Head Office

There is no statutory definition of a normal return for the purpose of ICTA88/S237 but the criteria used for deciding whether a normal return is exceeded are the same as the criteria used for determining whether a dividend is ‘abnormal’ under ICTA88/S709. ICTA88/S237 is therefore only to be invoked by Business Tax, Special Investigations Section 2 (SIS2), 22 Kingsway, London WC2B 6NR which is where Districts should submit any cases which appear to be caught by the legislation at ICTA88/S237. Any enquiry received from taxpayers or their advisors on the operation of ICTA88/S237 should also be referred to SIS2 before any response is made.