SCIT CORPORATION TAX – deductions – charges on income – qualifying donations – distributions – articles of association of company provided that the holders of the A shares could by ordinary resolution require the company to make gifts to any charity – the A shares were transferred to a charitable foundation which resolved that the company should make gifts to the charitable foundation – whether the payments were distributions ‘in respect of shares’ within the meaning of section 209(2)(b) – yes – whether section 209(4) applied to the gifts – yes – appeal allowed – ICTA 1988 Ss 209, 254, 338 and 339
Citations:
[2006] UKSPC SPC00521
Links:
Corporation Tax
Updated: 05 July 2022; Ref: scu.240284
