In Alexander Beard v HMRC [2022] TC08460, the First Tier Tribunal (FTT) found that distributions of share premium by a listed PLC incorporated in Jersey were subject to UK income tax as dividends and not capital gains tax.

The FTT found that the payments were dividends for UK tax purposes and should be subject to income tax accordingly finding:

Useful guides on this topic

Dividend Tax (freeview)
How do you tax dividend income? An at a glance guide to the dividend allowance and dividend tax rates.

Dividend tax (subscriber guide)
This practical tax guide explains how dividends are taxed on or after 6 April 2016. It includes HMRC's own examples, more detailed examples, including an Owner Managed Business (OMB) section together with tax planning tips.

How to appeal an HMRC decision
Disagree with an HMRC decision? How to appeal, what type of decision can you appeal and what are your different options when you disagree with HMRC? What are the key steps in making an appeal?

External links

Alexander Beard v HMRC [2022] TC08460

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