����Ӱ��

View the related checklists about Distribution

Digital assets and cryptoassets on death—checklist

Digital assets and cryptoassets on death—checklist The personal representatives (PRs) of an estate have a duty to administer the estate and this includes dealing with all the deceased’s digital assets, including online accounts and profiles even if they have no monetary or immediate value. While it is estimated that there are already over two million people in the UK who hold some form of cryptoasset, to date relatively few people have died with such assets in their estate and this is still a developing area of law and practice. More generally, the vast majority of the UK population is likely to have some sort of digital profile or digital asset in their estate on death. For information on what are considered to be digital assets, see Practice Note: Dealing with digital assets after death—What are digital assets? This Checklist deals with specific issues for PRs to consider where the estate contains digital assets, including cryptoassets. It focuses solely on issues relating to digital assets rather than physical assets and should...

EU AIFMD—timeline

EU AIFMD—timeline This timeline shows key developments relating to the Alternative Investment Fund Managers Directive (EU) 2011/61/EU (EU AIFMD) from January 2024 onwards. For earlier developments, see Alternative Investment Fund Managers Directive (AIFMD)—timeline [Archived]. For further guidance on EU AIFMD, see Practice Note: EU AIFMD—essentials. For further guidance on the UK Alternative Investment Fund Managers (AIFM) regime, see Practice Note: UK regulation of alternative investment fund managers—essentials. 2025 Date Source Document Description 24 April 2025 ESMA ESMA assesses the risks posed by the use of leverage in the fund sectorTRV Article: Risks in UCITS using the absolute Value-at-Risk approachTRV Article: Annual risk assessment of leveraged AIFs in the EU – 2024 The European Securities and Markets Authority (ESMA) has published its annual risk assessment of leveraged alternative investment funds (AIFs) and its first analysis on risks in the (Undertakings for the Collective Investment in Transferable Securities) UCITS using the absolute Value-at-Risk (VaR) approach. ESMA’s analysis identifies that while most EU funds utilise limited leverage, a subset of AIFs—particularly hedge...

View the related practice notes about Distribution

Scope of distributions for tax purposes

The most common type of distribution is a dividend paid in cash by a company to its shareholders, ie a direct cash distribution of profits to the owners of a company.However, the corporation tax definition of distribution is different from the company law definition (for which, see Practice Note: Dividends, distributions and scrip dividends).Why does it matter whether a payment is a distribution?It is important to be able to identify whether a particular payment by a UK company is a distribution because if a payment is a distribution:•the payer is not entitled to a deduction for the payment in its UK corporation tax calculation, and•a UK corporate recipient will be subject to corporation tax on the receipt in accordance with CTA 2009, Part 9A, unless the distribution falls within one of the specific exemptions—for further information, see Practice Notes: How are small companies taxed on distributions received? and How are non-small companies taxed on distributions received?Since most normal distributions will fall within one of the exemptions from tax, it is...

Tax—types of distribution—dividends

As further explained in Practice Note: Scope of distributions for tax purposes, distributions can be divided into four categories:•dividends—encompassing paragraph A and explained further in this note•transfers of assets or liabilities—encompassing paragraphs B and G and explained further in Practice Note: Tax-types of distribution—transfers of assets and liabilities•interest recharacterised as a distribution—encompassing paragraphs E and F and explained in further detail in Practice Notes: Types of distribution—interest recharacterised as a distribution: non-commercial securities and Types of distribution—interest recharacterised as a distribution: special securities, and•bonus issues of shares or securities—encompassing paragraphs C, D and H and explained in further detail in Practice Note: Types of distribution—bonus issuesParagraph A—dividendsThe first type of distribution is any dividend paid by the company, including a capital dividend.In order to determine whether a particular payment or transaction falls within this paragraph, it is necessary to understand the meaning of 'dividend' and 'paid'. Paragraph A makes no reference to cash and so this type of distribution can include a dividend paid in kind, subject to the exclusion...

View the related precedents about Distribution

Distribution agreement—non-exclusive—short form

Distribution agreement—non-exclusive—short form This Agreement is made on [date] Parties 1 [insert name of party] [of OR a company incorporated in England and Wales under number [insert registered number] whose registered office is at] [insert address] (Manufacturer); and 2 [insert name of party] [of OR a company incorporated in England and Wales under number [insert registered number] whose registered office is at] [insert address] (Distributor); each of the Manufacturer and the Distributor being a party and together they are the parties. Background (A) The Manufacturer manufactures [and supplies] the Products. (B) The Distributor has agreed to distribute the Products on a non-exclusive basis in the Territory in accordance with the provisions of this Agreement. The parties agree: 1 Definitions 1.1 In this Agreement: Active Sales • has the meaning given in Article 8(7) of VABEO; Affiliate • means any entity that directly or indirectly controls, is controlled by, or is in under common control with, another entity where “control” means the beneficial ownership of...

Letter recommending insurance—demands and needs—law firms

Letter recommending insurance—demands and needs—law firms   We have reached a stage in your matter where we believe it would be in your best interests to buy [insert type of insurance]. We have suggested you buy the insurance from [state name of insurance provider to whom you have introduced the client for insurance or who has given you delegated authority to issue a policy]. This is something we have already discussed and you have agreed that we will [state what you will do to arrange the insurance, eg complete and submit a proposal form on your behalf or issue the policy under delegated authority]. You have consented to us disclosing relevant personal data and information to [state name of insurance provider] for this purpose. Fees, charges and commission Insurance premium The [insert type of insurance] insurance policy costs £[insert amount or where it is not possible to give a specific amount, the basis for the calculation of the premium]. This is called the 'insurance premium'. [Explain what you...

View the related q&as about Distribution

If a UK resident non-domiciled individual receives a distribution of offshore income outside the UK, will this income be taxable in the UK?

If a UK resident non-domiciled individual receives a distribution of offshore income outside the UK, will this income be taxable in the UK? The income will not be taxable if: • it is not remitted to the UK • the individual who is entitled to the income is not deemed UK domiciled, and • the individual is a remittance basis user for the tax year in which the income arose See Practice Note: The remittance basis—summary. Note that the income will be deemed to have been remitted to the UK in certain circumstances (a ‘constructive remittance’). For example, suppose an individual borrows money outside the UK which they remit to the UK. If they use offshore income to repay the loan (outside the UK) then this will likely be a constructive remittance—see Practice Note: The remittance basis—meaning of relevant debt. Note also that there are complicated rules that apply if the income is mixed (eg in a bank account) with other funds; it may be impossible to remit...

An offshore trust is established by a non-domiciled settlor. The trust owns an offshore company which holds shares in a UK company. The settlor becomes UK resident non-domiciliary (res non-dom), but deemed UK domiciled. The beneficiaries include the settlor and other UK res non-dom (deemed dom) persons (including the beneficiaries). The UK company pays dividend to the offshore company, which in turn pays an equivalent dividend up to the trustee. The trustee makes a discretionary income distribution to the beneficiaries. Is there any exemption for income tax charge for the beneficiaries on account of settlors having already been taxed on the UK dividends arising in the offshore company under section 720 of the Income Tax Act 2007?

An offshore trust is established by a non-domiciled settlor. The trust owns an offshore company which holds shares in a UK company. The settlor becomes UK resident non-domiciliary (res non-dom), but deemed UK domiciled. The beneficiaries include the settlor and other UK res non-dom (deemed dom) persons (including the beneficiaries). The UK company pays dividend to the offshore company, which in turn pays an equivalent dividend up to the trustee. The trustee makes a discretionary income distribution to the beneficiaries. Is there any exemption for income tax charge for the beneficiaries on account of settlors having already been taxed on the UK dividends arising in the offshore company under section 720 of the Income Tax Act 2007? We have assumed that: • the distribution to the beneficiaries is within the scope of section 731 of the Income Tax Act 2007 (ITA 2007) • the income of the offshore company and the trust does not constitute ‘protected foreign source income’ within the meaning of ITA 2007, ss 721A and 729A...

View the related News about Distribution

Immigration weekly highlights—8 May 2025

Welcome to the 8 May 2025 highlights from the Immigration team, which provides links to key news stories from the last week, as well as a round-up of new and updated content in Immigration.

Planning weekly highlights—8 May 2025

This week's edition of Planning weekly highlights includes: a court decision determining neighbouring solar farms did not create a single ‘NSIP’ development; updates on the Planning and Infrastructure Bill, including the impact assessment and OEP and RIBA submissions on the Bill and guidance on non-urgent Crown Development applications.

View the latest UK Parliament Acts documents on Distribution

829 Meaning of “distribution”

829  Meaning of “distribution”(1)     In this Part “distribution” means every description of distribution of a company's assets to its members, whether in cash or otherwise, subject to the following exceptions.(2)     The following are not distributions for the purposes of this Part—(a)     an issue of shares as fully or partly paid bonus shares;(b)     the reduction of share capital—(i)     by extinguishing or reducing the liability of any of the members on any of the company's shares in respect of share capital not paid up, or(ii)     by repaying