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Shares without dividend rights are ordinary share capital (HMRC v McQuillan)

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Published on: 07 September 2017
Published by a LexisNexis Tax expert

Table of contents

  • Original news
  • What are the practical implications of this case?
  • What were the facts of the case?
  • What did the tribunal decide?
  • Case details

Article summary

Tax analysis: The Upper Tribunal (UT) has overturned a decision of the First-tier Tribunal (FTT) and held that shares with no dividend rights do not carry a ‘right to a dividend at a fixed rate’, and do therefore count as ordinary share capital for tax purposes.

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Jurisdiction(s):
United Kingdom

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