I am looking at doing a capital reduction for a client, and reducing their SPA by £400k, and transferring to distributable reasons.
For internal political reasons (!), the capital cannot be repaid to the shareholders, I definitely want it to go to the P&L. The shareholders are all non-resi, so no income tax implications on their subsequent dividends.
My question is, I cannot see any CT ramifications whatsoever. Am I missing anything?