Company share buy back

Company share buy back

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A company is setting up an insured company buy back arrangement. It is likley to meet the requirements for the s219 exemption for CGT treatment except for one minority shareholder who is non resident. The rules require any shareholder to be UK resident so for the this individual one assumes the purchase will be treated as a distribution.

Has anyone any experience of this and how the tax would operate for this individual? One assumes he just declares this as an overseas dividend in his own country of residence. 

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By Steve Kesby
03rd Oct 2013 19:26

It depends
UK tax law treats it as a distribution, because strictly it is.

It's excluded income for a non-UK resident.

How the UK treats it isn't relevant to the tax treatment outside the UK though. I can't see another country not taxing it as a distribution though, because that's what it is really.

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