This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) looks at the decisions in Beard and Rettig, as well as HMRC’s revised guidance on unallowable purpose.
Beard: whether dividends of a capital nature
The Court of Appeal in A Beard v HMRC [2025] EWCA Civ 385 had to interpret the meaning of ‘dividends of a capital nature’ in ITTOIA 2005 s 402(4). For income tax purposes there is a distinction between payments received from UK-resident and non-UK resident companies. UK income taxpayers are subject to income tax on any distribution (whether or not capital in nature) from a UK resident company but only on dividends not of a capital nature or other income received from...
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This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) looks at the decisions in Beard and Rettig, as well as HMRC’s revised guidance on unallowable purpose.
Beard: whether dividends of a capital nature
The Court of Appeal in A Beard v HMRC [2025] EWCA Civ 385 had to interpret the meaning of ‘dividends of a capital nature’ in ITTOIA 2005 s 402(4). For income tax purposes there is a distinction between payments received from UK-resident and non-UK resident companies. UK income taxpayers are subject to income tax on any distribution (whether or not capital in nature) from a UK resident company but only on dividends not of a capital nature or other income received from...
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:
