Grumpy Old Man
Striker
I’m only talking about capital gains, hadnt given any thoughts to a distribution. Although now I have I imagine a reorganisation of some sort could result in creation of reserves to get new profits (!) out.
That could only really have happened if the intercompany debt had been released, rather than capitalised. It would then show as a movement on reserves, rather than capital (see the recent accounts of Bolton and QPR for how this works). If you can meet the conditions, you could also possibly release the contents of the share premium account.