Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright) assess the practical impact of the Upper Tribunal’s decision in Gould.
Timing of interim dividends for income tax purposes
Dividends of UK resident companies are subject to income tax in the hands of shareholders for the period in which payment of the dividend becomes enforceable. The point at which the payment of a dividend becomes enforceable may be simple and uncontroversial but should not be taken for granted. This is particularly the case for interim dividends and shareholders with timing sensitivities should give particular consideration to the issues that may arise.
Enforceability of interim dividends
Where the Articles of Association are in the usual form (i.e. they draw a distinction between final dividends and interim dividends) the decision in Potel v IRC (1970) 46 TC 658 HC sets out the key principles to determine when an interim...
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Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright) assess the practical impact of the Upper Tribunal’s decision in Gould.
Timing of interim dividends for income tax purposes
Dividends of UK resident companies are subject to income tax in the hands of shareholders for the period in which payment of the dividend becomes enforceable. The point at which the payment of a dividend becomes enforceable may be simple and uncontroversial but should not be taken for granted. This is particularly the case for interim dividends and shareholders with timing sensitivities should give particular consideration to the issues that may arise.
Enforceability of interim dividends
Where the Articles of Association are in the usual form (i.e. they draw a distinction between final dividends and interim dividends) the decision in Potel v IRC (1970) 46 TC 658 HC sets out the key principles to determine when an interim...
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:
