Aziz Teimurov
Joined: 2/6/2022
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Personal income tax for non-residents from reduction of share capital
Company A is a UK resident company owned by physical entity B (non-resident in UK) Physical entity B made contribution to charter capital of Company A in kind (shares of Company C, legal entity from Kazakhstan). At the date of incorporation, equity capital of Company C was valued at GBP50 mln. After a few years, Company A sold its investment in Company C and obtained GBP50 mln. Physical entity B wants to reduce share capital of Company A by GBP50 and obtain the proceeds in the form of cash. What are the tax consequences for physical entity B if GBP50 mln is returned to physical entity B? -
Personal income tax for non-residents from distribution of equity
Company A is a UK resident company owned by physical entity B (non-resident in UK) Physical entity B made contribution to charter capital of Company A in kind (shares of Company C, legal entity from Kazakhstan). At the date of incorporation, equity capital of Company C was valued at GBP50 mln. After a few years, Company A sold its investment in Company C and obtained GBP50 mln. Physical entity B wants to redistribute GBP50 mln in the form od dividends. Is it possible to distribute GBP50 mln in the form of dividends? What are the tax consequences for physical entity B if GBP50 mln is distributed in the form of dividends?