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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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Groups & consortia: groups - entitlement to profits or assets available for distribution: varying rights for different accounting periods

ICTA88/SCH18/PARA5

The guidance in CTM81075 to CTM81085 applies in any case where an equity holder holds as such (CTM81010) shares or securities carrying rights in respect of:

  • dividend or interest, or
  • assets on a winding-up,

and those rights vary for different accounting periods.

Shares and securities have varying rights when, if

  • the distribution of profits, or
  • the winding-up,

were to take place in a different accounting period (that is not the relevant accounting period (CTM81005)), the percentage of such profits or assets to which that equity holder would be entitled would be different from the percentage determined in that relevant accounting period.

In such a case the instructions in CTM81075 to CTM81085 apply to determine:

  • the percentage of the profits available for distribution to equity holders to which the parent company is beneficially entitled, and
  • the percentage of the amount of the assets available for distribution to equity holders to which the parent company is beneficially entitled on a winding-up.