First Nationwide

May 2011 | Client publication/article

HMRC have lost their appeal in First Nationwide, the Upper Tribunal holding that a dividend paid out of share premium account was an "overseas dividend" for the purposes of the manufactured dividend rules, and a subscription was not a purchase for the purposes of the repo rules. Sara Luder, who acted for taxpayer in this case, reviews the decision.

This article was originally produced for the 06 May 2011 edition of Tax Journal.

See also:

Dividends paid from share premium - Mar 2012

First Nationwide and Dividends - Apr 2011

Capital Dividends - An Update - Mar 2010

Capital Dividends - An Update - Feb 2010

Can a dividend be capital in nature - Feb 2010

When is a dividend not a dividend - Jan 2010


Sara Luder (partner)

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