Dividends did not represent taxable income to the extent they were declared but withheld and unpaid, but had the appeal not been allowed, HMRC’s discovery assessments would have been valid.â¯
Summary
Dividends did not represent taxable income to the extent they were declared but withheld and unpaid, but had the appeal not been allowed, the discovery assessments issued by HM Revenue and Customs (HMRC) would have been valid.â¯
Background
The appellants (MJ and KJ) were shareholders of a property management company (QPL). They held the single issued share jointly. MJ was the sole director of QPL, and KJ was the company secretary. In the late 2000s, QPL entered into a number of loans with Lloyds Bank Plc (Lloyds) in connection with property purchases made. It also purchased, through Lloyds, ten interest rate hedging products, some of which were accepted by Lloyds to have
