The Distributions (Excluded Companies) Regulations 2009
From 1st July 2009, a dividend or other distribution which a small company receives from another company is exempt from the charge to corporation tax if the conditions set out in section 931B of the Corporation Tax Act 2009 (“CTA 2009”) (c.4) are satisfied. One such condition is that the payer is a resident of (and only of) the United Kingdom or a qualifying territory at the time that the distribution is received.