DIVIDEND-TAX

Oliver Marre

Oliver Marre (5 Stone Buildings) examines a recent Upper Tribunal decision that demonstrates a modern approach to both the dividend taxing provisions and the settlement provisions found in ITTOIA 2005.

Michael Anderson

Joseph Irwin

Michael Anderson and Joseph Irwin (Joseph Hage Aaronson) examine the recent High Court judgment that found largely in favour of HMRC.

Tim Sarson

Tim Sarson (KPMG) assesses the latest developments that matter in the international tax arena.

Simon Whitehead

Peter Stewart

Simon Whitehead and Peter Stewart (Joseph Hage Aaronson) review the recent decision in Six Continents, which considers what foreign profits should receive credit at the foreign nominal rate following an earlier ruling of the CJEU in the FII group litigation.

Ashley Greenbank

Ashley Greenbank (Macfarlanes) reviews the proposals on company distributions, which would amend the transactions in securities rules and introduce a new targeted anti-avoidance rule.

The CJEU embraces a ‘per-element approach’ and considers the limitation of certain tax advantages to purely national situations of tax-integrated groups to be a violation of the freedom of establishment.

Peter Vaines

The changes to the taxation of dividends proposed in the Budget seem to be worthy of rather more attention than they have received, writes Peter Vaines.