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HMRC internal manual

Company Taxation Manual

Particular bodies: clubs: incorporated as companies - dividends paid

If a company pays dividends, it will normally be liable to tax as a trading concern. However, if the other conditions in CTM40120 are satisfied, there is likely to be liability only where there is a marked inequality of shareholdings and the dividends are substantial.

Cases of doubt or difficulty, where the tax at stake is substantial, should be submitted to CTIS (Technical).