Corporation Tax Act 2009 section 974

Charge to tax under this Chapter

Section 974 establishes when corporation tax applies to income arising from the sale or realisation of dividend coupons attached to foreign holdings.

• Income from the sale or realisation of taxable dividend coupons on foreign holdings is subject to corporation tax as income
• The charge applies where a UK-based bank sells or realises taxable dividend coupons, or pays or accounts for the proceeds on behalf of another party
• The charge also applies where someone who is not a bank or coupon dealer sells taxable dividend coupons to a coupon dealer in the UK
• The taxable income is equal to the full proceeds of the sale or realisation