CheckLists.Tax (beta)
G4: Dividends and distributions
GENERAL
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Dividend
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Meaning of dividend
- Distribution paid out of share premium account using same mechanism as dividend on profit is a dividend (Beard v. HMRC [2024] UKUT 73 (TCC) §45)
Legislation:
Cases:
HMRC manuals:
Commentary:
See also:
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Form of payment determines whether capital or income
- Character of share premium account depends on the law applicable to it and the mechanism used to distribute it.
- Under Jersey law, share premium may be distributed using the ordinary dividend mechanism and is income. (Beard v. HMRC [2024] UKUT 73 (TCC) §68)
- The answer would be different if the mechanism used was reduction of share capital (Beard v. HMRC [2024] UKUT 73 (TCC) §72)
Legislation:
Cases:
HMRC manuals:
Commentary:
See also:
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Interim dividends
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No enforceable debt
- "The significance of this in present context is that a final dividend which has been properly declared and which does not specify a date for payment creates an immediately enforceable debt. If a final dividend is declared under the terms of a resolution that states that it is payable on a future date (a fairly common occurrence for quoted companies) then the debt is enforceable, and the dividend is due and payable, only on that later date. An interim dividend, on the other hand, may be varied or rescinded at any time before payment and may therefore only be regarded as due and payable when it is actually paid. The Potel case contains a clear exposition of this point at page 669." (CTM15205)
Legislation:
Cases:
HMRC manuals:
Commentary:
See also:
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INCOME TAX
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Distributions in respect of shares
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Person(s) liable
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- Indirect receipt through a series of steps by person not holding shares
Dividend received by shareholder through trust arrangement in pre-planned steps:
- "[73]In that regard, s 385 does not require the taxable person to be the holder of the shares on which the distribution is made. All that is required is that they are the person to whom the distribution is made or treated as made (subsection (a)), or the person receiving or entitled to the distribution (subsection (b)). The overarching purpose is to ensure that a shareholder who either does receive, or is entitled to receive, a distribution from a UK resident company is subject to income tax on that distribution.
[74] The effect of the Scheme was that Mr Dunsby directly received the payment of a dividend declared by the Company of which he was, prior to the Scheme, the sole shareholder. He was also entitled to the distribution, as the principal beneficiary under that Trust. Indeed the stated purpose of the Scheme, as recorded by the FTT, was “to allow the payment of dividends from UK resident companies free of income tax”. On that basis, it seems to us that the transaction fell squarely within both the scope and the purpose of ss 383–385 ITTOIA." (Dunsby, UT).
Legislation:
Cases:
Dunsby v. HMRC [2021] UKUT 289 (TCC), Bacon J and Judge Herrington;
HMRC manuals:
Commentary:
See also:
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- Look at who the distribution truly belong to, not the flow of funds
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- "[85] Our analysis is, however, fortified by the fact that viewed realistically there is no doubt whatsoever that Mr Dunsby was the “person to whom the distribution truly belongs”: the entire purpose and effect of the Scheme was to put the distribution in the hands of Mr Dunsby. It should not matter how precisely the flow of funds was implemented so as to put the dividend in the hands of the taxpayer." (Dunsby UT).
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Legislation:
Cases:
Dunsby v. HMRC [2021] UKUT 289 (TCC), Bacon J and Judge Herrington;
HMRC manuals:
Commentary:
See also:
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- Unlawful dividends have to be returned ​(no distribution out of the assets of the company)
- "[87] We therefore do not consider the Appellant would have been entitled, on the basis of the Kinlan decision, to retain the various cash payments and transfers of assets that he received in breach of the Companies Act prohibition. Our initial view at [73] above therefore stands. It follows that since the Appellant was, at the time of the various cash payments and transfers of assets, under an obligation to return them, they cannot have amounted to a “distribution out of assets of the company” within the meaning of section 209(2)(b) ICTA. Nor, for the same reason, would such payments and transfers have given rise to a distribution under section 209(4) ICTA – the value of any benefit received by the Appellant would have been zero, given his legal obligation to return the cash and other assets." (Baker)​
- See further Procedure.tax N2-12. Company law principles.
Legislation:
Cases:
Baker v. HMRC [2013] UKFTT 394 (TC), §87, Judge Poole
HMRC manuals:
Commentary:
See also: N2-12. Company law principles;
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Transactions in securities
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- Ordinary dividend is not a transaction in securities but distribution in winding up is
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- Laird Group plc v. IRC: "[42] Whether the company is in liquidation or continuing to carry on business as a going concern, therefore, the distribution of the undistributed profits of a company to the shareholders entitled thereto merely gives effect to the rights attached to the shares. The funds are released, in the one case from the liquidator's discretion to retain them for the purpose of the winding up, and in the other from the directors' discretion to retain them for the purposes of the undertaking. Given that the former is not "a transaction relating to securities", neither in my opinion is the latter. The relationship between the payment and the shares in respect of which it is paid is the same in both cases."
- Distribution in a winding up is now specifically included (ITA 2007, s.684(2)(f)).
Legislation: ITA 2007, s.684;
Cases: Laird Group plc v. IRC [2003] UKHL 54;
HMRC manuals: CTM36810;
Commentary:
See also:
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Settlements code
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- Working for a company for a fraction of true value may be a settlement of the income generated/dividends
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General rule
- A person may provide funds to a 'settlement' by entering into a service contract whereby funds that would ordinarily be received by them are diverted to a company.
- If the company is owned wholly by the individual, there may be no bounteous intent. But if it is owned by a trust/others there may be bounteous intent.
- Query whether the company income or the dividends are the income arising under the settlement (or both).
- Consider the three settlements charges (Settlor/spouse retains an interest; income paid to minor children of settlor; capital sum to settlor/spouse).
- See further
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Examples
- Crossland v. Hawkins - T was a director, but not a shareholder of a company which a trust for the benefit his children purchased 98% of the shares in using funds contributed by their grandfather. T agreed to serve the company for a modest salary whereas the company received large fees for T's services as an actor. Held: there was a settlement. "when eventually there is a fund of profit derived from Hawkins' services and a distribution of part of it to the trustees, again I see no difficulty in holding that the result of all that has gone before is that he has provided funds indirectly for the purposes of this settlement."
- IRC v. Mills - T, a promising actress, entered into a contract with a company owned by a trust of which she was the beneficiary. T expected a contract worth £30,000 per year, but the company paid her a salary of £400. The company entered into the contract with the third party. Dividends were paid to the trustees. Held: T was a settlor and the dividends were income arising under the settlement.
- "the source of the dividends was money paid for Miss Mills's work and money which but for the arrangement would have been received by her."
- "...funds, which ordinarily would have been received by Mr. Hawkins and by Miss Mills for their acting, were diverted to companies which were channels for their transmission to trustees. It is not the provision of services but of funds which comes within the section."
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Legislation:
Cases:
Crossland v. Hawkins 39 TC 493;
IRC v. Mills [1974] STC 130, HoL;
HMRC manuals:
Commentary:
See also:
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- Dividends on one class only/not declared in proportion to effective ownership: potential settlement
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Controlling shareholder deciding to issue dividend on one class rather than another can be a settlement
- "[72] ... I accept HMRC’s arguments that a decision by the controlling shareholder to only issue a dividend on one class of shares rather than another (B shares in this case in preference to A shares) can be an arrangement caught by s660A. This follows generally from expansive wording of section 660G(1) to include “arrangement” and the need to take a “broad and realistic view” of the arrangements as per Lord Hoffman in Jones v Garnett. A finding that to chose to pay a dividend on only one kind of share can be a settlement is consistent with the Tribunal’s findings in Buck, where the shareholder waived his own dividends in favour of his wife (where there was only one class of shares)." (Patmore)
- Young v. Pearce - preference shares with no voting rights but right to 30% net profit, allotted to wives of shareholders, was a settlement.​
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Apply settlements code charges
- If there is a settlement, consider the 3 settlement code charges (settlor/spouse retains an interest, income to minor child of settlor, capital payment to settlor/spouse).
- See
- i8. Distribution to beneficiary.
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Legislation:
Cases:
Young v. Pearce [1996] STC 743;
Patmore v. HMRC [2010] UKFTT 334 (TC), Judge Mosedale;
HMRC manuals:
Commentary:
See also:
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- Waiver of dividend as a settlement
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Waiving dividend in favour of another is a settlement
- "[17] ... These cases make it clear that there is no need for any formal legal trust or settlement to bring the statutory provisions into operation. The cases also provide authority for the proposition that a definite plan, including a relatively simple one, to use a company's shares to divert income falls within the meaning of an arrangement: see paragraphs 48-49 per Lord Walker. This, as I read it, is consistent with Lord Hoffmann's approval of the "realistic" view that the court should take of the matter: see paragraph 11 of the judgment. On that basis there was an arrangement in relation to each dividend." (Buck)
Settlement code charges
- Husband retained an interest in Buck due to spouse interest.
- Same would apply if dividend was paid to minor child (due to ITTOIA s.629).
- Other charges will depend on facts (e.g. capital sum to settlor/spouse).
- See
- i8. Distribution to beneficiary.
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Outright gift exemption for spouses cannot apply​
- If waiver is in favour of someone other than spouse/minor child, there would need to be some additional facts for a settlements code charge to apply.
- Where waiver is in favour of spouse, outright gift exemption cannot apply: "[21]...Here, income is diverted by means of a dividend waiver in anticipation of the declaration of a dividend. There is no "outright gift", merely a one-off waiver of any dividend that might be declared in respect of shares: and the shares in question are retained by the previous person making the waiver and not given to the other spouse." (Buck)
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Legislation:
Cases:
HMRC manuals:
Commentary:
See also:
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- Allocation of shares and dividends between spouses
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​Spouse's ownership not involving any bounty where in proportion to contribution
- To the extent that the spouse's entitlement to shares and/or dividends reflects what he/she paid or contributed, there is no element of bounty.
- Patmore:
- Husband and wife contributed 50% each to the purchase of shares in a company but wife only got 2% of the voting shares and some non-voting shares.
- FTT held that husband held 40.5 of his A shares on constructive trust for wife because she was entitled to half the shares acquired (§59).
- Allocation of the non-voting shares to wife was not gratuitous.
- Nor was the decision to pay disproportionate dividends on those shares to wife, to the extent that the dividend did not exceed wife's entitlement under the constructive trust (§73).
- There was a settlement/bounty as to the excess over wife's constructive trust entitlement (§74).
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Outright gift exemption
- Even if there is bounty, if the outright gift exemption applies, income is not attributed to the donor/settlor (ITTOIA s.624(1)).
- See C2. Gift by an individual.
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Waiver of dividend in favour of spouse is settlement
- See Buck, above.
- Outright gift exemption cannot apply (as there is no outright gift of an asset).
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Preference shares to spouse treated as a settlement
- Young v. Pearce - preference shares with no voting rights but right to 30% net profit, allotted to wives of shareholders, was a settlement.
- Settlement was (probably) of the shares rather than the dividend they generated.
- Preference shares had no voting rights, so they were substantially a right to income.
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Dividends used/intended to be used to benefit spouse (e.g. pay off joint debt)
- In Patmore, there was no original arrangement that the dividends to the wife would be paid to the husband.
- FTT said that the mere fact that dividends were actually paid to spouse was not enough to disapply the outright gift exemption (§§67 - 68).
- However, it was always the plan to use the dividends to pay off a debt owed jointly by the wife and husband.
- Accordingly, the exemption would not have applied (if needed), because related property was or might be payable for the benefit of the donor (§69).
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Legislation:
Cases:
Young v. Pearce [1996] STC 743;
Patmore v. HMRC [2010] UKFTT 334 (TC), Judge Mosedale;
HMRC manuals:
Commentary:
See also:
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- Parents arranging for minor children to have shares (settlement)
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- Copeman v. Coleman - Preference shares entitled to 10% preferential dividend allotted to children of shareholder/spouse for £10, subsequent dividend of £40 declared. Held: this was a settlement
- "it is impossible to come to any other conclusion but that this was not a bona fide commercial transaction, and it appears to me that there was a disposition within the meaning of the definition in Sub-section (9), or an arrangement in the nature of a disposition within the meaning of that Sub-section".
- Bird - Parents arranged for their minor daughters to take 60% of the shares in a company. Held to be a settlement.
- Further, father was settlor even though he used his position as executor of father's will to direct funds 'on behalf' of the children to the company by way of loan (§25).
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Legislation:
Cases:
Bird v. HMRC [2008] UKSPC 720;
HMRC manuals:
Commentary:
See also:
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- Services and loans/guaranteeing loans to company owned by children as a settlement
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- Butler v. Wildin: T's children acquired shares for a 'trifling sum' in a company set up to carry out a development project. T made loans to the company and guaranteed bank loans. Held that this arrangement was a settlement.
- "The risk that the development would not prove profitable and might result in loss was taken by the taxpayers."
- "the arrangement made by the taxpayers was clearly a reciprocal arrangement under which each contributed, whether by the provision of skill and services or by making temporary loans, to the common purpose of providing the shareholders of the company and so indirectly and to the extent of their shareholding the four older children with an income-producing asset free of risk and cost."
- Shares transferred later by an uncle were disregarded as not being part of the arrangement.
- Shares transferred later by father were their own settlement.
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Legislation:
Cases:
Butler v. Wildin [1989] STC 22;
HMRC manuals:
Commentary:
See also:
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- Attempt to transfer dividend to another (consider settlements legislation)​
Steps leading to settlement may be part of settlement
- "[94]...It is clear from Chamberlain that the creation of a settlement as part of a series of steps that pursue an overall plan does not in itself mean that the earlier steps are to be regarded as part of the settlement itself. But Chamberlain does not set out a general proposition that the steps leading to the creation of a settlement are always to be ignored when determining the scope of the settlement. Indeed Mr Jones did not himself take issue, as a matter of principle, with the FTT’s conclusion at [104(3)] that steps which form an integral part of the arrangements to create a structure under which the income of property becomes payable to others may be regarded as part of the settlement.
...
[96] Nevertheless, and without aspiring to set out any exhaustive test, itseems to us that at least for present purposes a relevant question to ask is whether the act of settlement, narrowly defined, has an economic logic that is freestanding and severable from the preparatory steps leading to that settlement. If it does, then (absent unusual circumstances) that is a strong indication that the preparatory steps are not to be regarded as integral to that settlement." (Dunsby)
Legislation:
Cases:
Dunsby v. HMRC [2021] UKUT 289 (TCC), Bacon J and Judge Herrington
HMRC manuals:
Commentary:
See also:
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Transfer of assets abroad
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- Distribution as a benefit for the purposes of matching
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- Query whether a dividend/distribution by a company to an individual shareholder can be a benefit for the purpose of matching income to benefits under ITA s.731.
- Shareholders have a right to receive dividends, if declared (Laird Group plc §36).
- Distribution in a winding up is a payment that "merely gives effect to the shareholders' rights; they receive only what is already theirs" (Laird Group §37).
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Legislation:
Cases:
Laird Group plc v. IRC [2003] UKHL 54;
HMRC manuals:
Commentary:
See also:
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Business investment relief
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- Unpaid dividend may be a further investment ​
- Further step required to turn unpaid dividend into investment
- Needs to be a further step which indicates that the shareholder is intending to reinvest the proceeds and put them at the disposal of the company (Allam, §128)
- May be possible to infer this if dividend left outstanding for material period of time or if interest is charged, depends on facts (Allam, §128).
- Dividend treated as a loan where declared on 19 December 2012 and paid on 13 March 2013 in circumstances where it was added to loan account and interest charged (Allam, §128)
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Legislation:
Cases: Allam v. HMRC [2021] UKUT 291 (TCC);
HMRC manuals:
Commentary:
See also:
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CAPITAL GAINS TAX
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Disposal of asset distributed
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- Dividend/distribution in specie
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- This will be a disposal of the asset by the company.
- Non arm's length transaction, so market value consideration.
- See
B1. Sale, disposal, assignment.
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Legislation:
Cases:
HMRC manuals:
Commentary:
See also:
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Matching trust gains to benefits (s.87 + s.89(2) + Sch 4C)
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- Distribution as a capital payment for the purposes of matching
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General position
- Query whether a dividend/distribution by a company to an individual shareholder can be a capital payment for the purpose of matching gains.
- Capital payment includes a payment, transfer of assets "and the conferring of any other benefit" (s.97(2)).
- Arguably not a benefit:
- Shareholders have a right to receive dividends, if declared (Laird Group plc §36).
- Distribution in a winding up is a payment that "merely gives effect to the shareholders' rights; they receive only what is already theirs" (Laird Group §37).
- But it does seem to be a payment or transfer of assets.​​​
- Perhaps it is a transaction at arm's length (s.97(1)(b)).
- HMRC accept that this can apply to connected party transactions.
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Exclusion for income
- For UK residents, a payment is excluded if it is chargeable to income tax (s.97(1)).
- No exclusion if it is chargeable to corporation tax.
- UK resident companies can be taxed on s.87 gains.
- For non-residents, a payment is excluded if it is received as income.
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Value of the capital payment
- The amount of a capital payment which is an 'outright payment of money' appears, implicitly, to be the amount of the payment (s.97(4)).
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Legislation: TCGA 1992, s.97.
Cases:
Laird Group plc v. IRC [2003] UKHL 54;
HMRC manuals:
Commentary:
See also:
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- Trust gains matched to capital distribution by close company etc. controlled by trustees
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General rule
- If:
(1) A capital payment is received from a close company/company that would be close if UK resident;
(2) The company is controlled by the trustees of a settlement;
then, it is treated as received from the trustees for the purposes of matching trust gains to benefits from the trust (s.96(1)).
- Control:
- Company is controlled by the trustees alone or together with the settlor/persons connected with the settlor (s.96(8)).
- Apply a modified version of CTA 2010, s.450/s.451 (s.96(10)).
- See detailed notes on matching in i9. Benefits provided by trust.​
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- Distribution in a winding up is a payment that "merely gives effect to the shareholders' rights; they receive only what is already theirs" (Laird Group §37).
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Legislation:
Cases:
HMRC manuals:
Commentary:
See also:
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CORPORATION TAX
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Charge to tax and exemptions
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- Charge to tax
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- "(1)The charge to corporation tax on income applies to any dividend or other distribution of a company, but only if the distribution is not exempt." (CTA 2009, s.931A)
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Legislation: CTA 2009, s.931A;
Cases:
HMRC manuals:
Commentary:
See also:
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- Meaning of small company
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General
- Apply test to company receiving distribution (not company paying).
- Company is small if it has a headcount of less than 50 and either:
(1) Turnover not exceeding £10m; or
(2) Balance sheet total not exceeding £10m
- Annualise for periods shorter than 1 year.​
- "Generally, where at the balance sheet date an enterprise goes over, or falls below, the staff headcount or financial thresholds, this will not result in a change of status until the position is repeated for the second consecutive year" (INTM652060).
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Partner and linked enterprises
- Aggregate all partners.
- Aggregate linked enterprises based on proportion of capital or voting rights held.
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Specific exceptions
- The following are not small companies (CTA 2009, s.931S):
Open-ended investment company
Authorised unit trust scheme
Insurance company
Friendly society.
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Legislation:
Cases:
HMRC manuals:
Commentary:
See also: Commission guidance;
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- Small company exemption (distribution received by small company)
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General
- Exemption applies where recipient is a small company (irrespective of paying company) if (CTA 2009, s.931B):
(1) Payer is solely resident in UK or qualifying territory at time of receipt.
(2) Distribution is not within CTA 2010, s.1000(1)E or F (distributions in respect of non-commercial or special securities).
(3) No deduction is allowed to a resident of any territory outside the UK in respect of the distribution under the law of that territory.
- HMRC say deduction is a broad concept, applying where the effect of the distribution is to reduce the rate of tax payable (INTM652030).
(4) Distribution is not made as part of a tax advantage scheme.
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Resident
- Company is resident in territory if liable to tax there by reason of domicile, residence or place of management (s.931C(3)).
- Does not apply if only liable to tax in respect of income from sources in that territory or capital situated there.
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Qualifying territory
- Territory with which double tax relief arrangements made + the arrangements contain a non-discrimination provision.
- Non-discrimination provision defined in s.931C(4).
- List of qualifying territories: INTM412090.
- Territories where certain companies are excluded by regulations: Antigua, Barbados, Cyprus, Jamaica, Malaysia, Malta (INTM652020).
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Tax advantage scheme/conduits
- Tax advantage includes relief from tax or the avoidance or reduction of a charge to tax (CTA 2010, s.1139).
- Tax means income tax or corporation tax (s.1119).
- Tax advantage scheme means a scheme with a main purpose of obtaining a tax advantage, other than a negligible advantage (CTA 2009, s.931V).
- HMRC appear to interpret the exclusion as applying where obtaining the exemption from CT was the purpose of the scheme, e.g. routing a dividend from a non-qualifying territory through a company in a qualifying territory (INTM652050).
- It seems difficult to justify applying the exclusion as applying based on other tax advantages given the broad scope of the exemption for dividends from group companies received by non-small companies.
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Legislation: CTA 2009, s.931B, 931C, 931V; CTA 2010, s.1119, s.1139.
Cases:
HMRC manuals: INTM652020; INTM412090;
Commentary:
See also:
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- Charge to tax
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XX
Legislation:
Cases:
HMRC manuals:
Commentary:
See also:
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INHERITANCE TAX
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Gift with reservation
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- Whether dividend arrangements following gift of shares give rise to a reservation of benefit
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- Continuation of existing reasonable commercial arrangements in the form of remuneration and other benefits for the donor's service in a business does not amount to a reservation, provided the benefits are not affected by the gift (IHTM14337).
- If new remunerative arrangements are made, HMRC will investigate whether it amounts to a reservation of a benefit.
- HMRC will normally disregard rights that can only be exercised in a fiduciary capacity (IHTM14395).
- This might be relied on where donor gifts shares to trust and exercises voting rights as trustee.
Legislation:
Cases:
HMRC manuals: IHTM14337; IHTM14395;
Commentary: McCutcheon 7-134;
See also:
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SDLT
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Distribution of interest in land
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- Exemption for distributions
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No chargeable consideration
- Ordinarily there is no consideration for a distribution, such that SDLT is not payable/the transaction is exempt (FA 2003, Sch 3, para 1).
Recipient takes over debt: chargeable consideration
- If the shareholder takes over debt owed by the company as part of the distribution (e.g. where the land is mortgaged), assuming the debt will be chargeable consideration.
- HMRC say that they will not apply this result where the debt is solely owed to the shareholder, unless perhaps the the shareholder debt replaced third party debt as part of the arrangement to distribute (SDLTM04042).
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Acquisition from connected company: deemed market value
- If the shareholder acquiring the interest in land is a connected company, the deemed market value rule may apply (s.53), however, there is an exclusion from that rule where the transaction is part of a distribution of the assets of the company (s.54(4)).
- Exclusion does not apply if the interest in land or an interest from which it is derived was the subject of a transaction on which group relief was claimed by the vendor within the past 3 years (s.54(4)). In that case, the deemed market value rule will apply.
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Legislation: FA 2003, s.53; s.54;
Cases:
HMRC manuals:
Commentary: SDLTM04042;
See also:
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- Purchase of company followed by distribution of land (s.75A)
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- A transfer of shares is ignored for the purposes of s.75A if it is the first of a series of scheme transactions (s.75C(1)). This means that the consideration for the transfer of shares is also ignored.
- Accordingly, in a simple case of purchase of a debt-free company followed by distribution of land, s.75A should not apply (SDLTM09380).
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Legislation: FA 2003, s.75C(1);
Cases:
HMRC manuals: SDLTM09380;
Commentary:
See also:
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- Funding company to clear third-party debt followed by distribution of land (s.75A)
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- HMRC's view is that if there is an issue of shares to raise funds to pay off a debt, which allows the property to be distributed, the share subscription monies will be chargeable consideration for a notional transaction under s.75A (SDLTM09420).
- This result may not apply where the discharging of the debt "has not occurred as part of the arrangements for the transfer of the property from the company to the shareholders" (SDLTM04042).
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Legislation:
Cases:
HMRC manuals:
Commentary: SDLTM09420; SDLTM04042;
See also:
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- Distribution of land to company followed by sale of that company (s.75A)
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- HMRC's view (SDLTM09430) is that s.75A will apply where, as part of an arrangement:
(1) an intermediate holding company (NewCo) is inserted between a holding company (HoldCo) and its subsidiary (SubCo);
(2) SubCo distributes properties to NewCo (exempt from SDLT);
(3) NewCo distributes the original subsidiary back to the holding company;
(4) HoldCo sells NewCo.
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Legislation:
Cases:
HMRC manuals:
Commentary: SDLTM09430;
See also:
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