Tax for UK PLCs and their shareholders

Corporation tax: 25 per cent, 19 per cent and the bit in between

A PLC pays corporation tax under the same rules as a private Ltd. The legal form does not change the rate. The main rate is 25 per cent and applies where profits exceed £250,000. With profits of £50,000 or less, the small profits rate of 19 per cent applies. In between, marginal relief provides a sliding transition from one rate to the other.

One detail that groups often miss: the £50,000 and £250,000 limits are reduced proportionally for short accounting periods and divided by the number of associated companies. A PLC with three subsidiaries does not get the full limits four times over. If you are planning a holding with several UK companies, run the numbers first.

And the question many remember from earlier debates: is the rate about to rise again? In the Budget of 28 October 2026 the government announced that the 25 per cent main rate and the 19 per cent small profits rate will stay for the financial year starting 1 April 2028 as well. For your planning, that means calm on this front, at least until then.

The PLC as a holding company: why the legal form rarely drives the tax

Many PLCs are holding companies. The PLC holds shareholdings, receives distributions from its subsidiaries and pays dividends to its own shareholders. Whether UK tax arises along the way depends on the type of income and on the UK exemptions for distributions, not on whether the name ends in Ltd or plc.

The tax logic of a UK holding company with shareholders abroad is set out in detail on the UK Holding Company page. Here we stay with what is specific to the PLC: dividends to shareholders abroad and stamp duty on shares. Why you would choose a PLC over a Ltd in the first place is a question for the formation stage.

Withholding tax on UK dividends: what applies to you as a shareholder abroad

This is the most searched question about UK shares of all: how much does the UK withhold from my dividend? HMRC treats dividends from a UK-resident company as so-called disregarded income in the hands of a non-resident. The wider picture of UK withholding tax on dividends has its own article; here is the core for PLC shareholders. The consequence is set out in the HMRC manual at SAIM1170: a non-resident's UK income tax on this income is limited to the tax deducted, or treated as deducted, at source.

In plain terms: as a shareholder living outside the UK, you owe the UK no more on your dividend than what is withheld when it is paid. The system does not envisage a UK top-up on the dividend. Whether your bank or broker deducts anything shows on your statement, and that is worth a look before you think about a refund claim.

Double tax treaties add a further cap on what the source country may take. Treaty rates are maximums: they limit how much the state where the dividend comes from may tax it. What that state's own law actually asks for can be lower. Which cap applies to you depends on the treaty between the UK and your country of residence, and on whether you hold privately or through a company.

Where the dividend is really taxed: at home

The tax that matters on your PLC dividend does not arise in London but where you live. Your country of residence decides how a UK dividend is taxed. Which tax applies, at what rate, and whether any partial exemption helps depends on your country, the size of your holding, and whether you hold the shares personally or through your own company.

That is why the old sales line "no withholding tax, so tax-free" is worthless. It only holds for someone living in a country that does not tax dividends. For everyone else, the tax moves; it does not disappear. If you are thinking about moving abroad, plan the PLC and the new residence together, not one after the other. That is a classic topic for a UK Tax Consult.

Stamp taxes on shares: stamp duty and SDRT

Now for the small British speciality. If you buy existing shares in a UK-incorporated company, you usually pay 0.5 per cent of the price. When the purchase runs electronically through CREST, it is called Stamp Duty Reserve Tax (SDRT) and is deducted automatically. When shares pass on a paper stock transfer form, it is stamp duty, and it only applies where the price is over £1,000.

Transfers outside CREST, so-called off-market transactions, also trigger SDRT. Nothing is deducted automatically then; HMRC must be told in writing. This is exactly where deadlines slip at unlisted PLCs. One shareholder sells to another, both assume it is a private matter, and the register is rewritten without anyone thinking about the tax. In our company secretary service we check this before the register entry is made.

Two exemptions matter for founders and issuers. If you subscribe for new shares, receiving freshly issued shares in a capital increase or at formation, there is no stamp tax. The same goes for shares you are given. It gets more expensive only for transfers into certain depositary receipt schemes or clearance services, where a rate of 1.5 per cent applies.

UK listing relief: three years without SDRT after listing

Since the Finance Act 2026 there has been a relief that counts at a listing. Shares in a company newly admitted to a UK regulated market carry no 0.5 per cent SDRT for the first three years after admission. The rule sits in section 89C of the Finance Act 1986 and applies to agreements from 27 November 2025 where the company was newly listed from that date.

Two limits come with it. First, the relief does not cover the 1.5 per cent rate, nor transfers as part of a takeover with a change of control. Second, it is tied to a UK regulated market, in practice the London Stock Exchange's Main Market. Under the exchange's own rules, AIM is a multilateral trading facility, not a regulated market. So this listing relief does not apply to AIM shares; different rules apply there, which we go through with you case by case.

For choosing a venue, it is one argument among many, not the main one. But it belongs in the numbers when you prepare taking your PLC public with us.

What is coming from 2027: the Securities Transfer Tax

Stamp taxes on shares are being rebuilt. In the 2026 Budget the government confirmed that a new Securities Transfer Tax is to replace stamp duty and SDRT from late 2027. The legislation comes in the Finance Bill 2026-27, and the exact start date will be set by later regulations.

Until then, today's rules apply unchanged. For you that mostly means one thing: if you are setting up a PLC's share register, transfer forms and articles now, build them so that a change of tax regime does not need new articles.

Sources: GOV.UK: Corporation Tax rates, expenses and reliefs; GOV.UK: Budget 2026, Overview of tax legislation and rates; HMRC Savings and Investment Manual SAIM1170: non-residents; GOV.UK: Tax when you buy shares; legislation.gov.uk: Finance Act 1986, section 89C (UK listing relief); GOV.UK: Stamp Duty Reserve Tax, UK Listing Relief; London Stock Exchange: AIM Rules for Companies (August 2026)