Speed Read: Following recent concerns that the corporate dividend exemption might not apply to certain dividends because HMRC regarded them as being capital in nature a recent ministerial statement states that the Finance Bill will restore previous expectations as to the tax treatment of distributions for corporate recipients. Whilst the statement is silent on this it is likely that this legislation will only apply to UK dividends. HMRC are also consulting on changes to the value shifting rules that might now apply whenever dividends are paid to materially reduce the value of a company so as to avoid CGT.
In my article published in Tax Journal on...
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Speed Read: Following recent concerns that the corporate dividend exemption might not apply to certain dividends because HMRC regarded them as being capital in nature a recent ministerial statement states that the Finance Bill will restore previous expectations as to the tax treatment of distributions for corporate recipients. Whilst the statement is silent on this it is likely that this legislation will only apply to UK dividends. HMRC are also consulting on changes to the value shifting rules that might now apply whenever dividends are paid to materially reduce the value of a company so as to avoid CGT.
In my article published in Tax Journal on...
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