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Home / Simons-Taxes /Corporate tax /Part D5 Company distributions /Division D5.1 Company distributions /Treatment of companies receiving distributions / D5.154 Non-small company distribution exemption—non-redeemable ordinary shares
Commentary

D5.154 Non-small company distribution exemption—non-redeemable ordinary shares

Corporate tax

Distributions will be exempt if they fall within one or more of the five exempt classes as summarised in D5.152. One of these is where the distribution is in respect of a share that is an ordinary share that is not redeemable1.

An ordinary share is defined as 'a share that does not carry any present or future preferential right to dividends or to a company's assets on a winding up'2.

A share is redeemable only if it is redeemable as a result of its terms of issue, or any collateral arrangements, requiring redemption, entitling the holder to require redemption, or entitling the issuing company to redeem3.

This definition infers that where an ordinary share is redeemable under a territory's relevant company law as distinct from the

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