A couple of taxpayer victories concerning the income tax treatment of dividends are among the developments reviewed by Edward Reed and Andy Carruthers (Macfarlanes).
Reaping the dividends
It is reasonably rare to see reported cases on dividends rarer still to see (no less than two) dividend cases where the taxpayer wins.
In Gould v HMRC [2022] UKFTT 431 (TC) the directors of a company resolved to pay an interim dividend. The amount due to one shareholder was paid promptly but the sum owed to a second shareholder was paid several months later in the following tax year by which point that shareholder was non-UK resident and so not taxable in the UK.
Interim dividends are subject to income tax in the hands of the shareholder when they become ‘due and payable’. HMRC argued that the interim dividend was enforceable by the...
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A couple of taxpayer victories concerning the income tax treatment of dividends are among the developments reviewed by Edward Reed and Andy Carruthers (Macfarlanes).
Reaping the dividends
It is reasonably rare to see reported cases on dividends rarer still to see (no less than two) dividend cases where the taxpayer wins.
In Gould v HMRC [2022] UKFTT 431 (TC) the directors of a company resolved to pay an interim dividend. The amount due to one shareholder was paid promptly but the sum owed to a second shareholder was paid several months later in the following tax year by which point that shareholder was non-UK resident and so not taxable in the UK.
Interim dividends are subject to income tax in the hands of the shareholder when they become ‘due and payable’. HMRC argued that the interim dividend was enforceable by the...
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:
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