Taxes Consolidation Act 1997 section 146

Provisions supplementary to section 145

Section 146 required a company whose distribution carried a reduced tax credit under section 145 to make a supplementary cash distribution equal to the shortfall, with no tax credit attaching to the top-up.

• Triggered where section 145 reduced the tax credit on a distribution made in respect of a right or obligation falling within section 139.
• The company had to pay a supplementary distribution equal to the difference between the tax credit that would normally have applied and the reduced credit allowed by section 145.
• The recipient was treated as receiving a single combined distribution but, by way of override of section 136, was not entitled to any tax credit on the supplementary element.
• The dividend voucher issued under section 152(1) had to show the supplementary distribution as a separate item.