CTM34260 - Residence: non-resident companies: securities in respect of which distributions may arise

The types of security in respect of which distributions may arise (see CTM15500) include securities issued by a company and held by its parent company or fellow subsidiary where the parent or fellow subsidiary is not resident in the UK. (This does not apply, however, where 90% or more of the share capital of the issuing company is directly owned by a company resident in the UK.) The parent/subsidiary relationship is to be determined in accordance with ICTA88/S838. The treatment of interest payments on this type of security may, however, be affected by the terms of the relevant Double Taxation Agreement (see DT1825).