Company distributions

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Autumn Budget 2026: Company distributions

The distributions framework for companies impacts the tax treatment of various transactions and structuring, including demergers and company purchases of own shares. Following consultation earlier this year, the government has provided an update and summary of the consultation responses received.

It has been confirmed that any changes to the distributions’ framework will be effective from 6 April 2028, and will broadly follow the original proposals. This is likely to bring some currently untaxed transactions or transactions charged to capital gains tax within the dividend income tax regime.

Draft legislation will be published for technical consultation in 2027, giving advisers an opportunity to consider the impacts of the new rules and provide responses to government before the new legislation comes into force in 2028.

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