When principal in group of companies relocated abroad, inter-group transfer of shares resulting was chargeable to corporation tax. Citations: Times 16-Mar-1998 Statutes: Income and Corporation Taxes Act 1988 278 Jurisdiction: England and Wales Corporation Tax Updated: 24 August 2022; Ref: scu.80172
SCIT INCOME TAX – Settlement – Company owned by husband and wife – Allotment of shares in company to their minor children on subscription at par – Payment of dividends to children – Whether settlement by virtue or in consequence of which dividends were paid within meaning of Income and Corporation Taxes Act 1988 ss. … Continue reading Bird and Another v Revenue and Customs: SCIT 3 Nov 2008
FTTTx INCOME TAX – loss relief – shares – s 574 ICTA 1988 – money held in director’s loan account – board resolution to allot shares – company secretary instructed to prepare and issue share certificate and to enter allotment in shareholders’ register – due to external circumstances, latter actions not taken – whether shares … Continue reading Saund v Revenue and Customs: FTTTx 3 Dec 2012
FTTTx CORPORATION TAX – Whether arrears of rent as between associated companies should be allowed on a bad debt, or disallowed for S74(1) ICTA 1988 – question of intention – Appeal Dismissed Citations: [2013] UKFTT 778 (TC) Links: Bailii Statutes: Income and Corporation Taxes Act 1988 74(1) Corporation Tax Updated: 17 November 2022; Ref: scu.472782
SCIT SETTLEMENT – Dividend waiver – Income arising under a settlement in which settlor retains interest – Arrangement – Company owned by husband and as to one share by wife – Husband waived dividend in relation to all his 9999 shares – Enhanced dividend consequently paid to wife in respect of her one share – … Continue reading Buck v Revenue and Customs: SCIT 23 Oct 2008
SCIT CAPITAL GAINS TAX – tax avoidance scheme – whether subscription for shares followed by the return of the subscription money by way of dividend (by an unlimited company), followed by disposal of the shares for a nominal amount five months after the subscription was a self-cancelling composite transaction – yes – whether HMRC can … Continue reading Eyretel Unapproved Pension Scheme and others v Revenue and Customs: SCIT 12 Nov 2008
INCOME TAX – losses from activities related to eleven properties purchased by Appellant and subsequently let – Appellant contending that properties were purchased with the intention of being sold at a profit within a short period, and were let temporarily when it became apparent that a deterioration in the property market made sale at a … Continue reading Azam v Revenue and Customs: FTTTx 14 Jan 2011
The court was asked whether the Commissioners had been correct to disallow in a closure notice, the attribution in part to income in the year 2000-01 of expenses incurred by the trustees of a United Kingdom resident discretionary trust. The expenses claimed were (i) trustees’ fees, (ii) investment management fees, (iii) bank charges, (iv) custodian … Continue reading HM Revenue and Customs v Trustees of the Peter Clay Discretionary Trust: CA 19 Dec 2008
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