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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
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 meaning of distribution? Indeed why is it such an important case outside the field of charities?
The case is of particular interest because the Special...

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