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HMRC internal manual

International Manual

Distribution exemption: Exemption for all other companies: meaning of "redeemable"

What do we mean by “redeemable”?

CTA09/S931U gives the meaning of “redeemable”. A share is redeemable for the purposes of CTA09/Part 9A if the terms of the share issue are such that the share capital must be redeemed, or that it may be redeemed by either the shareholder or the issuer. For this purpose any arrangements that are collateral to the share issue must also be taken into account.

See INTM654040 below regarding an anti-avoidance rule that may apply where a right to redemption of share capital arises otherwise than by the terms of the share issue.