Tax-types of distribution—transfers of assets and liabilities


Published by a ÀÏ˾»úÎçÒ¹¸£Àû Tax expert
Practice notes

Tax-types of distribution—transfers of assets and liabilities


Published by a ÀÏ˾»úÎçÒ¹¸£Àû Tax expert

Practice notes
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As further explained in Scope of distributions for tax purposes, distributions can be divided into four categories:

  1. •

    dividends—encompassing paragraph A and explained in further detail in Practice Note: Tax—types of distribution—dividends

  2. •

    transfers of assets or Liabilities—encompassing paragraphs B and G and explained further in this note

  3. •

    interest recharacterised as a distribution—encompassing paragraphs E and F and explained in further detail in Practice Note: Types of distribution—interest recharacterised as a distribution: non-commercial Securities, and Types of distribution—interest recharacterised as a distribution: special securities, and

  4. •

    bonus issues of Shares or securities—encompassing paragraphs C, D and H and explained in further detail in Practice Note: Types of distribution—bonus issues

Significant changes were made to the application of paragraphs B and G by Finance Act 2012 s 33, which have effect for distributions made on or after 17 July 2012. This practice note explains the law as it applies now, the exclusions that applied before 17 July 2012 and the changes that have been made.

Most importantly, a distribution falling within the scope of both

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United Kingdom
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Key definition:
Liabilities definition
What does Liabilities mean?

A scheme's liabilities are its future benefit payments and expenses. The scheme is in deficit if the current value of its liabilities is more than the assets, or in surplus if the liabilities are less.

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