In this month’s review, Sophie Dworetzsky (Charles Russell Speechlys) examines a case on distributions from an offshore company, a potentially farreaching proposed change to the definition of permanent establishment and the latest HMRC guidance.
Beard: whether distributions are income or capital
In Beard v HMRC [2025] EWCA Civ 385 (reported in Tax Journal 9 May 2025) the Court of Appeal (CA) upheld the decisions of the FTT and the UT that distributions of a Jersey company funded from share premium account were income in nature.
Between 2011 and 2016 the taxpayer received distributions of c.£150m from Glencore PLC a Swiss...
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In this month’s review, Sophie Dworetzsky (Charles Russell Speechlys) examines a case on distributions from an offshore company, a potentially farreaching proposed change to the definition of permanent establishment and the latest HMRC guidance.
Beard: whether distributions are income or capital
In Beard v HMRC [2025] EWCA Civ 385 (reported in Tax Journal 9 May 2025) the Court of Appeal (CA) upheld the decisions of the FTT and the UT that distributions of a Jersey company funded from share premium account were income in nature.
Between 2011 and 2016 the taxpayer received distributions of c.£150m from Glencore PLC a Swiss...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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