Corporation Tax Act 2010 section 999

Priority of negative rules

Section 999 establishes that the rules determining what counts as a distribution are overridden by specific exceptions set out elsewhere in the legislation.

• The distribution rules in this chapter do not apply where an express exception exists, meaning not every payment or transaction that looks like a distribution will be treated as one.
• Chapter 3 sets out specific matters that are not to be treated as distributions, even if they would otherwise fall within the general rules.
• Section 1075 provides for exempt distributions, particularly in the context of company demergers, and Schedule 12 to Finance Act 1988 excludes certain qualifying benefits arising when a building society transfers its business to a company.
• A comprehensive table of provisions related to the distribution rules can be found in section 1001, which serves as a useful reference point for identifying further exceptions and related rules.