Hi andy1,
There is guidance on capital contribution reserves at CTM15440.
It advises that if the payment is made from the reserve and does not take the form of a dividend, the tax treatment will depend on the whether the recipient is charged to Corporation Tax (CT) or Income Tax (IT).
.CTM15440 - Distributions: general: repayment of share capital: share capital/share premium reduction
In the case of IT, there is very little to go on.
It suggests that the payment could be capital distribution within TCGA92/S122 at CG57800, which advises:
""The receipt of a capital distribution is treated as a disposal of an interest in the underlying shares.
The normal computational rules apply unless the distribution is small compared with the value of the shareholding"".
CG57800 - Capital distributions: introduction
Please have a look at the guidance on small capital distributions (5% or less of the value of the shares at the date of distribution) at CG57835.
CG57835 - Small capital distributions: introduction
Thank you.