BIM24600 - Mutual trading: distributions: ICTA88/S491

Introduction and layout of guidance

What is now ICTA88/S491 was introduced to reverse the effect of the decision in Brogan v Stafford Coal & Iron Company Ltd [1963] 41TC305 - see BIM24550.

The following guidance covers:

BIM24605Distributions may be taxable on first principles
BIM24610To what does ICTA88/S491 apply?
BIM24615What is taxed?
BIM24620Taxable as receipt of trade or post cessation receipt
BIM24625Allowable deductions and reliefs where recipient’s trade permanently discontinued
BIM24630What are capital assets for ICTA88/S491?