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J Frye v HMRC

In J Frye v HMRC (TC01916 – 4 April) a UK citizen (F) received a dividend of £159 559 from a Bahamian trust. F failed to declare this on his tax return and HMRC issued an assessment charging tax on it. The First-tier Tribunal upheld the assessment and dismissed F’s appeal.

Why it matters: The Tribunal upheld HMRC’s view that a substantial dividend from an overseas trust was chargeable to income tax and rejected the appellant’s contention that it should be treated as capital.


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