19 Arrangements offering a choice of capital or income return
Finance Act 2015 (2015 c 11) | Legislation

19  Arrangements offering a choice of capital or income return

(1)     Chapter 3 of Part 4 of ITTOIA 2005 (dividends etc from UK resident companies and tax [treated as paid] in respect of certain distributions) is amended in accordance with subsections (2) to (6).

(2)     After section 396 insert—

“Other amounts treated as distributions

396A Arrangements offering a choice of capital or income return

(1)     Subsection (2) applies if a person (“S”) has a choice either—

(a)     to receive what would (ignoring this section) be a distribution of a company, or

(b)     to receive from that company, or from a third party, anything else (“the alternative receipt”) which—

(i)     is of the same or substantially the same value, and

(ii)     (ignoring this section) would not be charged to income tax.

(2)     If S chooses the alternative receipt—

(a)     for income tax purposes

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