HMRC have lost their appeal in First Nationwide, the Upper-tier Tribunal holding that a dividend paid out of share premium account was an ‘overseas dividend’ for the purposes of the manufactured dividend rules, and a subscription was not a purchase for the purposes of the repo rules.
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HMRC have lost their appeal in First Nationwide, the Upper-tier Tribunal holding that a dividend paid out of share premium account was an ‘overseas dividend’ for the purposes of the manufactured dividend rules, and a subscription was not a purchase for the purposes of the repo rules.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes: