D5.150 Companies receiving distributions—overview
Distributions paid by a UK or overseas company to a UK resident company are chargeable to corporation tax on the recipient unless the distribution is exempt1. The legislation is within CTA 2009, Part 9A and the only requirement for Part 9A to apply is whether the payment in question is a 'dividend or other distribution' (see D5.102). If it is, then the charge to corporation tax on income will apply, subject to the application of the distribution exemption regime in Part 9A. Any dividends not falling within an exempt category will therefore be fully taxable. Credit for overseas tax suffered is available, for details see Division D4.9.
For the treatment of individual recipients of distributions see Division E1.4
Small and non-small corporate recipients
When determining if a distribution is exempt, two different regimes
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