Stocklending agreement – deduction for management expenses in respect of manufactured dividends – para 1(1), Sch 23A ICTA – 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’ – yes – ss 737A and 730A ICTA – whether a sale of preference shares and a subscription for preference shares is a sale and repurchase of securities – no – appeal dismissed
Citations:
[2011] UKUT 174 (TCC)
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 13 September 2022; Ref: scu.440820