Related Commentary  Related HMRC Manuals

931E(1)  A dividend or other distribution falls into an exempt class if condition A or B is met.

931E(2)  Condition A is that the recipient controls the payer.

931E(3)  Condition B is that–

(a)the recipient is one of two persons who, taken together, control the payer,

(b)the recipient has interests, rights and powers representing at least 40% of the holdings, rights and powers in respect of which the recipient and the second person fall to be taken as controlling the payer, and

(c)the second person has interests, rights and powers representing–

(i)at least 40%, but

(ii)no more than 55%,

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