Company B (non-resident in UK) is owned by Company A (51% ownership of Company B, UK resident, incorporated in UK, owned by relatives of James) and James (49% ownership of Company B, non-resident in UK).
Company B is a profitable entity and pays an annual dividend.
Company A and James mutually agree that all dividends paid by Company B will be distributed to James only and Company A will not receive any dividends.
Are the any tax risks for Company A in such an arrangement (Company A owns majority stake in Company B and does not receive any dividends)?
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