In Beard v HMRC [2025] EWCA Civ. 385 the Court of Appeal rejected the taxpayer’s appeal, upholding the earlier Upper Tribunal (UT) and First-tier Tribunal (FTT) decisions that distributions received were dividends but were not of a capital nature and were therefore chargeable to income tax. The UT decision (Beard v HMRC [2024] UKUT 73 (TCC)) was discussed in “Direct Tax Cases: Decisions from the UK Courts”, Irish Tax Review, 37/2 (2024).
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