HMRC loses husband-and-wife settlements case

The Revenue claimed tax was due on dividends paid as part of a settlement under the Income and Corporation Taxes Act 1988. However, in a decision published this month, the First-Tier tribunal found in favour of the couple. Tribunal judge Barbara Mosedale concluded an arrangement under which David Patmore paid his wife dividends on non-voting B shares in their company did not fulfil the criteria for an s660a settlement. In the late 1990s, Mr and Mrs Patmore paid £320,000 to buy the small manufacturing company for which Mr Patmore worked. The husband and wife jointly funded a sha...