The Commissioners for HM Revenue and Customs v First Nationwide: [2011] UKUT 174 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Warren and Judge Sadler on 18 April 2011.

Read the full decision in The Commissioners for HM Revenue and Customs v First Nationwide: [2011] UKUT 174 (TCC).

Stock lending agreement – deduction for management expenses in respect of manufactured dividends – para 1(1), Sch 23A ICTA – Income Tax (Manufactured Overseas Dividends) Regulations 1993 – whether dividends paid by a Cayman Islands company out of share premium account are “dividends” and “overseas dividends” - yes – ss 737A and 730A ICTA – whether a sale of preference shares and a subscription for preference shares is a sale and repurchase of securities – no – appeal dismissed.

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