FTTTx 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’ – ss 737A and 730A ICTA – whether a sale of preference shares and a subscription for preference shares is a sale and repurchase of securities
Citations:
[2010] UKFTT 24 (TC)
Links:
Statutes:
Income Tax (Manufactured Overseas Dividends) Regulations 1993
Income Tax
Updated: 17 August 2022; Ref: scu.408883
