Ask an expert: IHT implications on a dividend waiver

Question

My client company (A) has a majority shareholding in a company (B) which has one other shareholder (an individual C). It is proposed that my client will waive its entitlement to a future dividend from B leaving C to receive a dividend payment. Company A and company B are both close companies and there is no other connection between A and C. Are there any inheritance tax consequences for my client in permitting a dividend to be paid to C and are there any other issues to be aware of?

Answer

A shareholder can execute a dividend waiver and leave a dividend in a company so that larger sums are available for other shareholders. As the waiving shareholder will receive no consideration the waiver should be minuted...