[2010] UKFTT 24 (TC)

[The appeal against this decision is reported at [2011] BTC 1,640.]

Judge Roger Berner (Chairman)

Decision released 12 January 2010

Stocklending agreement – deduction for management expenses in respect of manufactured dividends – ICTA Sch. 23A, para. 1(1) – Income Tax (Manufactured Overseas Dividends) Regulations 1993 – whether dividends paid by a Cayman Islands company out of share premium account are ‘dividends’ and ‘overseas dividends’ – ICTA ss. 737A and 730A – whether a sale of preference shares and a subscription for preference shares is a sale and repurchase of securities

Need help? Get subscribed!

To subscribe to this content, simply call 0800 231 5199

We can create a package that’s catered to your individual needs.

Or book a demo to see this product in action.