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Decision Number: |
Spc 00716 |
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Appellant:
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Stafford Robert Buck |
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Respondent:
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Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
Sir Stephen Oliver QC
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Date Of Decision:
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23/10/2008 |
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Main Category:
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INCOME TAX/CORPORATION TAX |
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Main Subcategory:
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Appeal |
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Notes:
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SETTLEMENT – Dividend waiver – Income arising under a settlement in which settlor retains interest – Arrangement – Company owned by husband and as to one share by wife – Husband waived dividend in relation to all his 9999 shares – Enhanced dividend consequently paid to wife in respect of her one share – Dividend income paid to wife – Whether waiver arrangement constituted a settlement – Yes – Whether element of bounty in arrangement – Yes – Appeal dismissed – Income and Corporation Taxes Act 1988, ss 660A(1) and 660G(1)
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Decision(s) to Download:
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Spc00716.doc 
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