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HMRC internal manual

International Manual

Distribution exemption: Exemption for small companies: further guidance

Some further points

There is further guidance on the EC Recommendation at CIRD91000. However, when applying this guidance for CTA09/Part 9A purposes, note that the modifications of the EC Recommendation at CTA09/S1120 (previously FA00/SCH20/PARA2) do not apply for Part 9A purposes.

Additionally, certain types of company are not treated as small companies for Part 9A purposes (see INTM652080).