In HMRC v P Gould [2024] UKUT 285 (TCC) (17 September) the Upper Tribunal (UT) dismissed HMRC’s appeal against the decision of the First-tier Tribunal (FTT) that an interim dividend was ‘paid’ for income tax purposes in 2016/17 when it was received by the shareholder.
Peter Gould (PG) and Nicholas Gould (NG) were the principal shareholders of Regis Group (Holdings) Ltd (Regis). On 31 March 2016 the board of directors which included PG and NG resolved to pay an interim dividend of £40m. The dividend was paid to NG in 2015/16. It was paid to PG in respect of the same share class in 2016/17 when he was not UK resident.
HMRC argued that for income tax purposes PG should be treated as having received his interim dividend at the same time as NG (i.e. at a time when he was still UK resident). A dividend...
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In HMRC v P Gould [2024] UKUT 285 (TCC) (17 September) the Upper Tribunal (UT) dismissed HMRC’s appeal against the decision of the First-tier Tribunal (FTT) that an interim dividend was ‘paid’ for income tax purposes in 2016/17 when it was received by the shareholder.
Peter Gould (PG) and Nicholas Gould (NG) were the principal shareholders of Regis Group (Holdings) Ltd (Regis). On 31 March 2016 the board of directors which included PG and NG resolved to pay an interim dividend of £40m. The dividend was paid to NG in 2015/16. It was paid to PG in respect of the same share class in 2016/17 when he was not UK resident.
HMRC argued that for income tax purposes PG should be treated as having received his interim dividend at the same time as NG (i.e. at a time when he was still UK resident). A dividend...
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