The case of First Nationwide v Commissioners for HMRC 2010 UKFTT 24 TC considered the meaning of “dividend” and the Court held that dividends paid out of the company’s share premium account were income in nature.
The Tax Appeals Commissioner held that intangible rights inherent in owning a share (such as the right to a distribution) were, in fact, assets – the asset is not only the share itself but, in addition, each right attaching to the share is also an asset. 10TACD2016
Whether the transfer of rights attaching to a class of shares to another class of shares was chargeable to income tax as a distribution 24TACD2018