A company that issues non - share equity interests will have a notional account called a non - share capital account . This account records contributions to the company in relation to those non - share equity interests and returns made by the company of those contributions.

A non - share distribution that represents a return of contributions is not taxed as a dividend (subject to the anti - avoidance provisions dealing with dividend substitution). In certain circumstances a company may use its share capital account as the source for such distributions.