Consultation: Modernising the taxation of distributions and repayments of capital from companies

HMRC have published a consultation on modernising the taxation of distributions and repayments of capital from companies.

The consultation focuses on shareholders within the charge to Income Tax and explores potential reforms to the tax treatment of various scenarios, including reductions of share capital, demergers and the company Purchase of Own Shares rules. It also considers changing the tax rules on distributions from non-UK resident companies so that they align with the rules on distributions from UK resident companies.

HMRC are also seeking views on proposals to replace the Transactions in Securities (TIS) rules with an updated anti-avoidance regime.

The ATT will be responding to the consultation and would welcome feedback from members for consideration as part of our response. Please [email protected] with any comments before 31 July 2026.