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 – Dividend income paid to wife – Whether waiver arrangement constituted a settlement – Yes – Whether element of bounty in arrangement – Yes – Appeal dismissed – Income and Corporation Taxes Act 1988, ss 660A(1) and 660G(1).
Citations:
[2008] UKSPC SPC00716, [2009] WTLR 215, [2009] STC (SCD) 6
Links:
Statutes:
Income and Corporation Taxes Act 1988 660A 660G
Income Tax
Updated: 21 July 2022; Ref: scu.278755