Nationwide - success in dispute against HMRC

25 Apr 2012

Slaughter and May advised Nationwide in relation to a substantial dispute with HMRC regarding the tax treatment of a structured finance transaction. The Court of Appeal (agreeing with both the First Tier and the Upper Tier Tribunals) found in Nationwide’s favour on all counts. This decision provides a precedent value for a number of ongoing disputes between various corporates and HMRC relating to tax planning involving the payment of dividends. It also raises interesting issues more generally which potentially have far-reaching consequences for the tax treatment of dividends. HMRC are not appealing this decision.


Tax: Sara Luder (partner), Edward Milliner (associate); Dispute Resolution: Ewan Brown (partner), James Stacey (associate)

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