Weil Tax BLOG - Feed https://tax.weil.com/category/uk-tax/interpretation/ Views and developments from the Tax Department at Weil Tue, 14 Apr 2026 20:54:30 +0000 hourly 1 Ordinary Share Capital: Clarity in Relation to Dividend Rights https://tax.weil.com/uk-tax/uk-focus-latest-thinking/ordinary-share-capital-clarity-in-relation-to-dividend-rights/ Sun, 01 Oct 2017 17:10:06 +0000 Oliver Walker Stuart Pibworth http://tax.weil.com/?p=483 The Upper Tribunal has overturned the decision of the First-tier Tribunal in McQuillan v HMRC, finding that non-dividend bearing redeemable shares constituted ordinary share capital for the purposes of section 989 of the Income Tax Act 2007 (section 989) ([2017] UKUT 344 (TCC)) (see Focus “Ordinary share capital: can a negative prove a positive?”, www.practicallaw.com/2-631-2725).

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]]> The Upper Tribunal has overturned the decision of the First-tier Tribunal in McQuillan v HMRC, finding that non-dividend bearing redeemable shares constituted ordinary share capital for the purposes of section 989 of the Income Tax Act 2007 (section 989) ([2017] UKUT 344 (TCC)) (see Focus “Ordinary share capital: can a negative prove a positive?”, www.practicallaw.com/2-631-2725).

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]]> Weil on the Move – Episode 2 – QCB or Non-QCB: That is the Question https://tax.weil.com/uk-tax/straight-to-the-point/weil-on-the-move-episode-2-qcb-or-non-qcb-that-is-the-question/ Tue, 05 Sep 2017 14:27:50 +0000 Oliver Walker Stuart Pibworth http://tax.weil.com/?p=481 The recent U.K. Court of Appeal decision in Hancock v HMRC raises the interesting (and important) question of the U.K. tax treatment of reorganizations involving qualifying corporate bonds (QCBs) and non-qualifying corporate bonds (non-QCBs). Although often thought of as one of the more certain areas of personal taxation, the Hancock decision has thrown some doubt

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]]> The recent U.K. Court of Appeal decision in Hancock v HMRC raises the interesting (and important) question of the U.K. tax treatment of reorganizations involving qualifying corporate bonds (QCBs) and non-qualifying corporate bonds (non-QCBs). Although often thought of as one of the more certain areas of personal taxation, the Hancock decision has thrown some doubt

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]]> Two Types of Bond https://tax.weil.com/uk-tax/uk-focus-latest-thinking/two-types-of-bond/ Thu, 13 Jul 2017 17:12:08 +0000 Oliver Walker Stuart Pibworth http://tax.weil.com/?p=479 It is often lamented that the advance of texting and social media has led to the unfortunate proliferation of acronyms and abbreviations that now haunt our daily lives. However, tax practitioners are no strangers to this phenomenon: the tax regime is littered with cumbersome terms that have long been subject to abbreviation and are thrown

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]]> It is often lamented that the advance of texting and social media has led to the unfortunate proliferation of acronyms and abbreviations that now haunt our daily lives. However, tax practitioners are no strangers to this phenomenon: the tax regime is littered with cumbersome terms that have long been subject to abbreviation and are thrown

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]]> Ordinary Share Capital: Can a Negative Prove a Positive? https://tax.weil.com/uk-tax/straight-to-the-point/ordinary-share-capital-can-a-negative-prove-a-positive/ Wed, 17 Aug 2016 12:50:08 +0000 Oliver Walker Stuart Pibworth http://tax.weil.com/?p=465 The recent decision in McQuillan v HMRC highlights the challenges faced by taxpayers seeking to apply correctly those parts of the UK tax code that require interpretation in the absence of conclusive definition ([2016] UKFTT 305 (TC)). McQuillan addresses whether shares with no dividend rights can be said to carry a fixed rate of dividend

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]]> The recent decision in McQuillan v HMRC highlights the challenges faced by taxpayers seeking to apply correctly those parts of the UK tax code that require interpretation in the absence of conclusive definition ([2016] UKFTT 305 (TC)). McQuillan addresses whether shares with no dividend rights can be said to carry a fixed rate of dividend

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