The Commissioners for HM Revenue and Customs v Stephen Warshaw [2020] UKUT 0366 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Meade and Judge Thomas Scott on 14 October 2020.
Read the full decision in
CAPITAL GAINS TAX – entrepreneurs’ relief – “personal company” – whether a 10% cumulative preferential dividend which is compounded for unpaid dividends is a dividend “at a fixed rate” – no, therefore shares carrying such rights are ordinary share capital – appeal dismissed