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Posted Tue, 05 Sep 2023 21:05:18 GMT by JackTh
A UK tax resident is a shareholder in a non-UK company (EU based company). The company has accounting profits for the running year, none of which have been issued in the form of dividends to any shareholder. However, the tax authorities in which the company operates, treats any such accounting profits for the running year as a deemed distribution of dividends (DDD) for the purposes of income taxation of Cyprus tax resident shareholders (but not for UK tax resident shareholders). Does this have any income tax implications for the UK tax Resident? In other words, does the UK tax Resident need to report any dividends to HMRC, given that no dividends were actually paid or distributed?
Posted Thu, 07 Sep 2023 13:56:05 GMT by HMRC Admin 19

The guidanceat CTM15205 advises "A dividend is not paid, and there is no distribution, unless and until the shareholder receives money or the distribution is otherwise unreservedly placed at the shareholder’s disposal, for instance by being credited to a loan account on which the shareholder has power to draw". 

CTM15205 - Distributions: general: dividends, distributions and company law

If you have not received anything, then there is no dividend to declare.

Thank you.

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