DIVIDEND

Mike Lane

This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) looks at the decisions in Beard and Rettig, as well as HMRC’s revised guidance on unallowable purpose.

Ritchie Tout

FA 2025 Sch 6 introduces some fundamental and far-reaching changes to the Employee Ownership Trusts (EOT) tax rules. HMRC view the changes as pure anti-avoidance to provide them with the tools to counter the undoubted abuse of the EOT tax...

Court of Appeal finds that distributions debited to company’s share premium account were dividends that were not capital in nature

Emma Rawson OBE

The corporation tax rates rules can be complex. Emma Rawson (ATT) looks at the particular difficulties facing corporate members of LLPs.

Oliver Marre

Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and its implications going forward.

Court of Appeal confirms that dividend replacement scheme failed.

Sophie Hatton

Artem Vasyutin

As a territorial tax regime, the UK has a number of benefits, which have only increased over the last two decades, write Artem Vasyutin and Sophie Hatton (Deloitte).

Aiden Hepworth

Dominic Stuttaford

Two recent cases provide a reminder of the extent to which taxation outcomes can depend on other areas of law and demonstrate that HMRC will not be limited to ‘pure’ tax law arguments on appeal, write Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright).

Irfan Butt

Andrew Seidler

Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures.

Constantine Christofi

Adam Craggs

Adam Craggs and Constantine Christofi (RPC) examine the First-tier Tribunal decision in Marlborough DP Ltd v HMRC that suggests the shortcomings in HMRC’s general approach following Rangers.

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