Client had a UK company(100%) in the UK, this was sold to a foreign company 15 years ago in exchage for shares in the holding company, share for share transfer. Last year the holding company sold the subsiadiary, 1 June 2018. On 15 June the holding company ceased trading. On 16 June a capital distribution was made to the shareholders. The holding company is being liquidated but this is done over 3 year because of the the earn out payments and funds held ESCROW. Apparently, in the country where the holding company is based there is no requirment to appoint a liquidator, all they need to do is to sign a shareholders resolution which has been done. My question is, can we claim ER on the capital distribution? In my opinion, the distribution is capital and qualifies for ER. Any thoughts will be much appreciated.