Recent cases have upset the conventional wisdom about the tax treatment of corporate distribution rights. This presentation places these decisions in context and explores current and future developments in corporate fund-raising with special reference to the following:
- what distributions are dividends under s6?
- what makes a dividend taxable under s44 after Condell?
- circumstances in which non-dividend distributions are taxable after the High Court’s decision in McNeil and the Governments consequent annoucement
- structuring rights issues.