The Weekly Law Reports
[2022] 1 WLR 2359
Supreme Court
*Coal Staff Superannuation Scheme Trustees Ltd
v
Revenue and Customs Commissioners
[2022] UKSC 10
2021 Oct 26, 27; 2022 April 27
Lord Reed PSC, Lord Hodge DPSC, Lord Briggs, Lord Sales, Lord Hamblen JJSC
Revenue— Income tax— Dividends— Taxpayer lending overseas shares in exchange for sum equivalent to dividends received by borrower during loan term— Borrower required to deduct amount equivalent to withholding tax on gross amount of such “manufactured overseas dividends”— Taxpayer unable to recover deducted tax if exempt from income tax— Whether tax regime for manufactured overseas dividends restricting free movement of capital— Whether taxpayer entitled to any remedy—
Income and Corporation Taxes Act 1988 (c 1), Sch 23A, para 4
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