HMRC v First Nationwide [2011] UKUT 174 (TCC) (18 April 2011)
"Stocklending agreement – deduction for management expenses in respect of manufactured dividends – para 1(1), Sch 23A ICTA – Income Tax (Manufactured Overseas Dividends) Regulations 1993 – whether dividends paid by a Cayman Islands company out of share premium account are "dividends" and "overseas dividends" - yes – ss 737A and 730A ICTA – whether a sale of preference shares and a subscription for preference shares is a sale and repurchase of securities – no – appeal dismissed"
