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Gould and the taxation of dividends

06 January 2025 / Pete Miller
Issue: 4967 / Categories: Comment & Analysis , debt , dividends , FTT , partnership , Business , Companies , Partnerships
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Pete Miller analyses the case of Gould on the taxation of dividends.

Once upon a time there were two brothers. Peter and Nicholas Gould owned a successful business Regis that decided to pay a dividend of £40m. So an interim dividend of £20m each was declared on 31 March 2016. £20m was paid to Nicholas on 5 April which was helpful as payment the next day ie in tax year 2016-17 would have carried a higher rate of income tax.

Peter’s dividend payment was delayed. He lived in Jamaica and worked in the US but he was finding it hard to open a bank account in Jamaica. Also for family reasons he had spent a lot of time in the UK during tax year 2015-16 so his residence status was not clear. Therefore he preferred to have his dividend paid in tax year 2016-17 when he was...

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