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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: effective rights

ICTA88/SCH18/PARA5B (5) to (9) provide that:

  • 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.

is the lowest possible percentage to which the parent company would be entitled if any combination of outstanding option rights at any time in the accounting period became effective.

For this purpose:

  • ‘outstanding option rights’ mean option rights which have not yet been put into effect,
  • option rights are put into effect at the point when the related shares or securities are acquired, and
  • option rights, which are not yet exercisable or not yet capable of being put into effect, are included.