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HMRC internal manual

Company Taxation Manual

Particular Trades: mutual concerns: distributions


A company which carries on mutual business, that is

  • mutual trading,
  • mutual insurance, or
  • other mutual business

will be treated as making a distribution within CTA10/PART23 only so far as it is a relevant distribution made out of profits brought into the charge to corporation tax, or out of franked investment income.

A relevant distribution means a distribution made to a person who participates in the mutual activities of the business and which derives from those activities. See BIM24555 onwards.

ACT is not payable by a company on distributions made on or after 6 April 1999.

CTIS (Technical) will advise if necessary.