B Share Scheme fails – Clipperton v HMRC [2021] UKFTT

Aparna Nathan QC (leading Laura Poots of Pump Court Tax Chambers) successfully argued, in relation to a scheme marketed to directors and shareholders of owner managed companies as a dividend replacement strategy, that the sums received by the directors and shareholders constituted a dividend or distribution under s383 ITTOIA or, in the alternative, that the arrangements were caught by the Income Tax Settlements legislation at ss619 et seq. ITTOIA 2005.

To read the full decision, please click here.

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