Repayments of share capital do not generally give rise to distributions for tax purposes (in particular, they are specifically excluded from the most likely category of ‘distributions out of assets of the company in respect of shares’ (paragraph B of CTA 2010, s. 1000(1); see ¶743-400).

Bonus issues are not generally distributions for tax purposes except in the case of a bonus issue of redeemable shares (paragraph C of CTA 2010, s. 1000(1); see ¶743-450).

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