Oil ring-fence: The decision of the Court of Appeal of the Falkland Islands in Sentinel Marine Falkland Islands Ltd v The Commissioner of Taxation (SC/CIV/03/21) (12 October 2022) concerns the scope of the oil ring-fence in the Falkland Islands. Perhaps of slightly more interest was whether the relevant provisions in the double tax treaty with the UK were discriminatory. The appellant’s argument that ring fenced trade legislation was discriminatory because it affected companies outside the Falkland Islands more than companies within the Falkland Islands was dismissed. The judge commented: ‘The various companies are under the legislation treated in exactly the same way. There just happen to be more UK companies.’ Read the decision.
Timing of paying dividends: Those who advise owner-managed companies will know that there is often informality in the way in which dividends are paid and declared. In most cases this does not create problems but where...
