The Commissioners for HM Revenue and Customs v First Nationwide: [2011] UKUT 174 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Warren and Judge Sadler on 18 April 2011.
Read the full decision in .
Stock lending agreement 鈥� deduction for management expenses in respect of manufactured dividends 鈥� para 1(1), Sch 23A ICTA 鈥� Income Tax (Manufactured Overseas Dividends) Regulations 1993 鈥� whether dividends paid by a Cayman Islands company out of share premium account are 鈥渄ividends鈥� and 鈥渙verseas dividends鈥� - yes 鈥� ss 737A and 730A ICTA 鈥� whether a sale of preference shares and a subscription for preference shares is a sale and repurchase of securities 鈥� no 鈥� appeal dismissed.
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Published 1 December 2016