On the payment of a dividend to shareholders on different dates, the later dividend was due and payable when it was paid, not in the tax year when the earlier dividend was paid. 

Summary 

On the payment of a dividend to shareholders on different dates, the later dividend was due and payable when it was paid, not in the tax year when the earlier dividend was paid. 

Background 

The appellant (PG), one of the principal shareholders in a company (R) established by his father (FG), worked full-time in the business with his brother (NG). R’s shareholders were PG, NG, and the trustees of a settlement under which PG and NG were joint life tenants.  

In 2015, following the death of his mother, PG decided to relocate to Jamaica. In late 2015 and early 2016, R’s financial controller recommended that R should pay a dividend. Following PG’s relocation to