On 23 June 2026, HMRC published a consultation titled Modernising the taxation of distributions and repayments of capital from companies.

The consultation proposes fundamental reform to the rules governing how payments from companies to their shareholders are taxed. Although the primary focus is on individual shareholders and trusts, the consultation will also impact corporates. It has the potential to be one of the more consequential consultations on UK tax law in decades.

In this episode of our Tax Focus podcast, the second in a mini-series, Maddy Gowlett and Hannah Manning discuss the proposals to reform demergers and the loans to participators regime.

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