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The taxation implications of company law reform
A discussion document
December 1993
Annex 2.2: Mechanisms for Taxing the Dividend Component
Shareholder | REPURCHASING COMPANIES | ||||
---|---|---|---|---|---|
Resident Non-Qualifying Company | Resident Qualifying Company | Non-Resident Company | |||
On-Market selective only | Off-Market pro rata or selective | Off-Market pro rata or selective | On Market | Off-Market | |
Resident Non-Corporate | Dividend exempt to recipient. Debit to ICA | Ordinary dividend treatment. ICA, RWT credits attached | Ordinary dividend treatment. ICA, RWT credits attached | No Tax | Ordinary dividend treatment |
Resident Corporate | As above | As above | As above | No Tax | As above |
Resident Vendor Taxable on share gain |
As above plus tax on gain | As above plus tax on gain over and above dividend | As above plus tax on gain over and above dividend | No Tax | As above plus tax on gain over and above dividend |
Resident Tax Exempt | Debit to ICA | Ordinary dividend treatment (exempt) | Ordinary dividend treatment (exempt) | No Tax | Ordinary dividend treatment |
Non-Residents | No NRWT. Debit to ICA | Ordinary dividend NRWT deduction |
Ordinary dividend NRWT deduction |
No Tax | No Tax |