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Briefing – Can a dividend be capital in nature?

Speed Read: The First Tier Tax Tribunal has held that certain dividends paid by a Cayman company out of share premium were still income in nature because following the payment of the dividends the corpus of the shares was still intact. Because the corporate dividend exemption does not apply to dividends of a capital nature this is also a current issue for the tax treatment of share redemptions and dividends paid out of distributable reserves created on the cancellation of share capital. The Tribunal also held that a subscription for shares was not a 'purchase' for the purposes of the repo rules.
When a shareholder receives a dividend that receipt is income in nature in the hands of the shareholder because a dividend by its very nature is fundamentally income in...

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