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Posted Fri, 23 Aug 2024 23:12:06 GMT by Douglas Taylor
We have a subsidiary company (100% owned) in the Isle of Man. We are looking at winding it up and paying the retained earnings as a liquidation dividend to its UK based holding company.
Will there be any tax payable by the UK company on that dividend?
I understand that dividends paid by the UK company to its shareholders from that dividend obviously fall within the normal tax rules on dividends. Or at least I think so.
Posted Wed, 28 Aug 2024 14:04:47 GMT by HMRC Admin 13 Response
Hi,
You can find guidance about exempt distributions at INTM650000 - Distribution exemption: contents - HMRC internal manual.
General guidance about distributions can be found at CTM15120 - Distributions: general: introduction - HMRC internal manual.
Thank you

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