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Posted Tue, 15 Aug 2023 12:47:35 GMT by
I held a few ordinary shares in a listed Swiss company. I received distribution of capital contribution reserves in cash from that company. What should be the tax treatment of this distribution? Should I consider this cash payment same as cash dividend or not?
Posted Thu, 17 Aug 2023 11:04:23 GMT by HMRC Admin 25
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. 
Posted Thu, 17 Aug 2023 12:02:52 GMT by
Thank you for you answer. This is very helpful. Quick follow-up question: In my case capital distribution relresents c. 0.5% of the value of the shares at the the time of that distribution. As I understand, this makes it a small capital distribution (pls correct me if I'm wrong). Given this background, what would be the tax treatment? Would i be charged to income tax? Also, would this distribution go towards my dividend allawance?
Posted Fri, 18 Aug 2023 10:50:39 GMT by HMRC Admin 25
Hi andy1,
It would come under Capital Gains Tax,  but if less then £12300 for 22/23 no charge would be due.
The limit is £6000 for capital gains 23/24.
Thank you. 
Posted Tue, 22 Aug 2023 10:24:41 GMT by
Thank you. I recieved dividends and capital gains in the amount that is well below corresponding tax allowances (i.e. no tax charge due). Do I have to disclose those amounts in Self Assessment? If yes, how do I correct the record for the previous tax year (since I've already submitted self assessment for that year without these amounts)? For the avoidance of doubt, I paid correct amount of tax, so that it's only a question of incomplete disclosure and how to correct it.
Posted Fri, 25 Aug 2023 15:28:21 GMT by HMRC Admin 25
Hi andy1,
As they are within the allowances it won't change your calculation, but you can do it online as an amendment (if you filed the original online).
If not, you can send in a letter giving the details of the dividends.
You dont need to show the capital gains.
Thank you. 

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