As a lawyer I am frequently being asked about the treatment of dividends with the abolition of ACT.
In particular, what is the position if pre-abolition the dividend is stated in the articles of association as being, for example, 7%. Can you let me know if there is any difference if the articles refer to 7% inclusive of any imputed tax credit, or if they are silent on the point. Also in drafting dividend rights now, should there be any reference to imputed tax credit?
Many thanks for your help.
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