Netherlands Distributions

Netherlands Distributions

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 HMRC guidance in Oct 2014, concerning foreign distributions from share capital to a UK company says:

"With regard to application of section 1025 CTA 2010, which treats a repayment of share premium as forming part of the share capital where the premium account was created in respect of new consideration received on the issue of the share capital, HMRC will normally, depending on application of the foreign company law, not treat a payment of out of a share premium account as a repayment of share capital in circumstances where under the foreign company law share premium is fully distributable and is not treated as forming part of the share capital."

Does any one know, or better still ,have experience of whether HMRC considers that a Netherlands distribution from share premium is "fully distributable and not treated as forming part of the share capital". Thanks!

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