Sharon Clipperton and Steven LLoyd v The Commissioners for His Majesty's Revenue and Customs [2022] UKUT 00351 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Adam Johnson and Judge Thomas Scott on 20 December 2022
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INCOME TAX - dividend avoidance scheme involving trust - whether taxable dividend or distribution received by taxpayers - whether settlements legislation overrode any charge under distribution code - application of settlements legislation - element of bounty requirement - whether taxpayers were settlors - application of multiple settlor provisions
Published 20 December 2022