Weil Tax BLOG - Feed https://tax.weil.com/category/uk-tax/structuring/ Views and developments from the Tax Department at Weil Fri, 29 May 2026 16:24:17 +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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]]> Demergers – Breaking Up is Never Easy https://tax.weil.com/uk-tax/straight-to-the-point/demergers-breaking-up-is-never-easy/ Mon, 04 Sep 2017 19:51:40 +0000 Oliver Walker Erica Rees Ellie Marques http://tax.weil.com/?p=480 In the new, post-Brexit referendum world, it appears that demergers have largely fallen out of favour. Although there are likely numerous tax, political and economic factors behind the reduction in demergers, the introduction of section 77A of the Finance Act 1986 (1986 Act) (section 77A), which applies to share transfers executed on or after 29

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]]> In the new, post-Brexit referendum world, it appears that demergers have largely fallen out of favour. Although there are likely numerous tax, political and economic factors behind the reduction in demergers, the introduction of section 77A of the Finance Act 1986 (1986 Act) (section 77A), which applies to share transfers executed on or after 29

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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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