Corporation Tax Act 2010 section 1072

Members of a 90% group

Section 1072 extends the meaning of "distribution" for companies that belong to a 90% group, broadening it to cover distributions made in respect of shares or securities of other group members.

• For a company in a 90% group, a "distribution" includes anything distributed out of the company's assets (cash or otherwise) in respect of shares in or securities of another company in the group.
• This extended meaning operates alongside, and does not limit, the existing rules on non-dividend distributions in respect of shares found elsewhere in the Corporation Tax Acts.
• The extended definition does not require a company to be treated as making a distribution to another company in the same group if that other company is UK resident.
• A "90% group" means a company together with all of its 90% subsidiaries — that is, subsidiaries in which the parent holds at least 90% of the ordinary share capital.