Corporation Tax Act 2010 section 1113

"In respect of shares"

Section 1113 explains what "in respect of shares in the company" means for the purposes of the distributions rules, particularly where a company belongs to a 90% group, and clarifies when something is regarded as done "in respect of a share".

  • Where a company is part of a 90% group, "in respect of shares in the company" covers shares in that company or any other company in the same group
  • The group-wide meaning does not require a company to be treated as making a distribution to another UK-resident company in the same group
  • Something is done "in respect of a share" if it is done to a person as the current or former holder of that share, or if it is done under a right granted or offer made in respect of that share
  • A "90% group" means a parent company together with all of its 90% subsidiaries

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