Corporation Tax Act 2009 section 931A

Charge to tax on distributions received

Section 931A establishes the basic principle that dividends and other distributions received by a company are subject to corporation tax on income, unless they qualify for an exemption.

• All dividends and other distributions received by a company are in principle chargeable to corporation tax on income.
• The charge applies to both UK and foreign distributions alike.
• A distribution escapes the charge only if it qualifies as exempt under specific rules for small companies (Chapter 2) or for companies that are not small (Chapter 3).
• The default position is therefore taxable — exemption must be positively established under the relevant chapter.