In DT Patmore v HMRC (TC00619 – 3 August) the controlling director of an engineering company wished to retire. He and his family held 85 of the 100 issued shares with the remaining 15 being held by the other director (P). In January 2000 P purchased 83 of the 85 shares giving him a 98% shareholding while his wife purchased the other two shares. (The share purchase was funded by a mortgage on a house which was jointly owned by P and his wife.) In March 2000 these 100 shares were renamed A shares and a further 10 B shares were issued and allotted to P’s wife. Between April 2000 and September 2002 dividends totalling £141 000 were paid on the 100 A shares while dividends totalling £79 000 were paid on the 10 B shares held by P’s wife. HMRC subsequently issued amendments...
