- FTT finds that distributions paid by Jersey company out of share premium were dividends of an income nature for UK tax purposes (Beard v HMRC)
- Why it matters
- Case details
Tax analysis: In Beard v HMRC, the First-tier Tax Tribunal (FTT) decided that payments debited from a capital account, such as a share premium account, in Jersey are no more ‘assimilated to capital’ than payments from any other type of account from which distributions can be legally made. If the relevant local law does not define share premium as assimilated to share capital, it must fall into the only other category of funds held by a company available to its shareholders, distributable profit, and as such is available to be paid by a company by way of dividend.
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