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Distribution Planning Pays Dividends

Thomas Lloyd-Jones and Elizabeth Sherwood of Macfarlanes LLP discuss the recent First-tier tax tribunal case of PA Holdings Ltd and Kully Janjuah v HMRC
In May 2009 the First-tier Tax Tribunal heard PA Holdings Ltd and Kully Janjuah v HMRC [2009] UKFTT 95. The case considered whether dividends paid on shares in a special purpose company from cash which might otherwise have been used to pay bonuses were dividend income or employment income or both. Such arrangements were common remuneration planning the crux of which was two-fold. First dividend receipts — taxed as distributions — attracted income tax at 25% rather than the 40% rate that applied to employment income received by higher rate taxpayers. Second the declaration of a dividend (unlike the payment of employment income)...
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