Jurisdiction(s):
United Kingdom

Key definition

Distribution definition

What does Distribution mean? In tax practice, a distribution is a transfer of value by a company to its shareholders in respect of their shares, most commonly a dividend but also non-cash (in specie) and other shareholder returns. For UK corporation tax, “distribution” is a defined term in cta 2010, s 1000. That provision sets out categories treated as distributions and important exclusions. Broadly, it covers cash dividends; other transfers out of a company’s assets in respect of shares; certain redemptions or repayments; and amounts treated as distributions where returns on securities depend on the company’s results or are excessive. Exclusions include genuine...

Client will instruction questionnaire (England and Wales), including executors, guardians, gifts, residue, overseas assets, and Finance Act 2025 residence‑based IHT and remittance basis changes

Published by a LexisNexis Private Client expert

Precedents

STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime.

Finance Act 2025 (FA 2025), which attained Royal Assent on 20 March 2025, enacts measures removing the remittance basis of taxation and substituting a residence-based system, taking effect from 6 April 2025.

FA 2025 likewise also displaces domicile as the primary determinant of exposure to inheritance tax.

Further reforms cover the following key areas:

revisions to the tests used for excluded property status,
ending the protected settlements status for offshore trusts,
and alterations to the overseas workday relief.

For further detail, consult Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26.

See also the Finance Bill Tracking Service: Key dates (Finance Bill 2025) and Finance Act 2025.

This questionnaire assists us in making an initial assessment of your needs and allows us to deliver the best advice in the light of your particular circumstances. It is also advisable for us to have a meeting to discuss the details further...

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Web page updated on 22/05/2026

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