First NationwideMay 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.
Sara Luder (partner)
Publications and seminars landing page