Dividends and distributions

FORTHCOMING CHANGE: At Autumn Budget 2024, the Labour government confirmed that it will proceed with the former Conservative administration's plans to abolish the remittance basis of taxation for non-UK domiciled individuals and replace it with a residence-based regime, to commence on 6 April 2025. The government also confirmed its intention to move to a residence-based regime for inheritance tax. The changes will also affect the rules determining excluded property status, the abolition of protected settlements status of offshore trusts, and changes to overseas workday relief. For information on these changes, including draft legislation published with Autumn Budget 2024, see Practice Note: The abolition of the remittance basis of taxation from 2025–26, News Analysis: Autumn Budget 2024—Private Client analysis—International, News Analysis: Autumn Budget 2024—reforming the taxation of non-doms, Autumn Budget 2024 (paras 2.56 and 5.51), OOTLAR (para 1.3) and TIIN: Reforming the taxation of non-UK domiciled individuals..

What is a distribution?

A distribution for corporation tax purposes means any of the following:

A
any dividend paid by the company, including a capital dividend
B
any other distribution out of assets of

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