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Dividend
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DIVIDEND
Tax and the City review for June 2025
Zoe Andrews
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.
FA 2025 review: EOTs: common sense prevails
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...
A Beard v HMRC
Court of Appeal finds that distributions debited to company’s share premium account were dividends that were not capital in nature
Corporation tax rate complexities for corporate LLP members
Emma Rawson OBE
The corporation tax rates rules can be complex. Emma Rawson (ATT) looks at the particular difficulties facing corporate members of LLPs.
Clipperton revisited: open questions
Oliver Marre
Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and
its implications going forward.
S Clipperton and another v HMRC
Court of Appeal confirms that dividend replacement scheme failed.
UK holding companies: why they are still holding strong?
Artem Vasyutin
Sophie Hatton
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).
Timing of dividends for income tax purposes
Dominic Stuttaford
Aiden Hepworth
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).
The new Luxembourg/UK double tax treaty
Irfan Butt
Andrew Seidler
Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures.
Remuneration trusts: the importance of facts
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
.
Go to page
of
3
EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
NEWS
Read all
Budget capital allowances changes: mixed picture for business investment decisions
Government declines to expand land remediation relief
HMRC publish new RTI guidance for employers
ERS: annual returns after scheme closure
CBAM: technical guidance on emissions reporting
CASES
Read all
Abbey Group Ltd v HMRC
Strauss Phillips & Co Ltd v HMRC
Education Training Collective v HMRC
Other cases that caught our eye: 30 October 2026
ScottishPower (SCPL) Ltd and others v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
The Nigel Blackwell Family Trust and others v HMRC
One minute with... Helen Miller
Chancellor reportedly rejects alignment of CGT and income tax rates
ScottishPower (SCPL) Ltd and others v HMRC
Side-by-Side: four scenarios for 2030