In the Corporation Tax Acts “distribution”, in relation to a company which is a member of a 90% group, includes anything distributed out of assets of the company (whether in cash or otherwise) in respect of shares in or securities of another company in the group.

Subsection (1) is without prejudice to paragraph B in section 1000(1) (distributions, other than dividends, in respect of shares) as extended by section 1113(1).

Nothing in subsection (1) requires a company to be treated as making a distribution to any other company which is in the same group and is UK resident.

In this section “90% group” means a company and all its 90% subsidiaries.