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HMRC internal manual

International Manual

HM Revenue & Customs
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Distribution exemption: Exemption for small companies: conduit schemes

What we mean by “tax advantage scheme”

A scheme to route a dividend from a company in a non-qualifying territory through a third company in a qualifying territory is likely to be a tax advantage scheme.

This will be the case even if the third company is carrying on business in the qualifying territory, if the dividend is routed through that company in order to obtain the advantage of distribution exemption.