Sharon Clipperton and Steven LLoyd v The Commissioners for His Majesty's Revenue and Customs [2022] UKUT 00351 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Adam Johnson and Judge Thomas Scott on 20 December 2022

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 20 December 2022

• Category: Tax
• Release date: 20 December 2022

Read Full Decision in Sharon Clipperton and Steven Lloyd v HMRC UT-2021-000070

INCOME TAX - dividend avoidance scheme involving trust - whether taxable dividend or distribution received by taxpayers - whether settlements legislation overrode any charge under distribution code - application of settlements legislation - element of bounty requirement - whether taxpayers were settlors - application of multiple settlor provisions

Published 20 December 2022