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.
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CAPITAL GAINS TAX 鈥� entrepreneurs鈥� relief 鈥� 鈥減ersonal company鈥� 鈥� whether a 10% cumulative preferential dividend which is compounded for unpaid dividends is a dividend 鈥渁t a fixed rate鈥� 鈥� no, therefore shares carrying such rights are ordinary share capital 鈥� appeal dismissed
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Published 23 December 2020