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Charitable Donation or Distribution?

Maurice Parry-Wingfield, Tax director in Deloitte's Tax Policy Group, analyses the Special Commissioners' findings in Noved and discovers they make a significant contribution to the meaning of company distributions

 
Maurice Parry-Wingfield Tax director in Deloitte's Tax Policy Group analyses the Special Commissioners' findings in Noved and discovers they make a significant contribution to the meaning of company distributions
 
It's not that unusual for a charity to own shares in a company even control it and receive donations from it under the corporate tax equivalent of Gift Aid. It wouldn't occur to many of us that the donation might constitute a distribution but that was the issue in Noved Investment Co v HMRC SpC 521. What was special about the case? More generally what does it tell us about the...

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