Corporation Tax Act 2009 section 931RA

Chargeable gains

Section 931RA clarifies that exempt dividends and distributions can still be relevant when calculating chargeable gains for corporation tax purposes.

• A dividend or other distribution may be exempt from corporation tax under the exemption rules
• However, that exempt status does not remove the dividend or distribution from chargeable gains calculations
• This ensures that chargeable gains computations remain accurate and complete, even where the underlying distribution is itself exempt
• This provision prevents companies from assuming that an exempt distribution can be entirely disregarded in all tax computations