Dividend payment dates: In Gould v HMRC [2022] UKFTT 431 (TC) (1 November 2022) two brothers held equal numbers of shares in their family company and wanted to extract £20m each by way of dividend. For their own tax reasons it suited them to be taxed on the dividends in different years. The dividends were authorised at a meeting on 31 March 2016 but no date for the payment was specified. Matters were so arranged that brother A received his dividend on 5 April 2016 and brother B on 16 December 2016 i.e. in different tax years. The question was before the FTT was when the dividends were paid. More precisely the issue was whether it was possible to have dividends on the same class of shares paid on different dates to different shareholders.
HMRC’s argument was essentially that the two dividends must be treated as being due...
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