We have a situation where a company was set up to do a barn conversion into several homes. The final properties are now sold, which is going to give a fairly decent final profit in the final accounts (quarter of a million) split over 2 shareholders. They don't want to do a capital liquidation (they have good reason, so that's not in point here). So, we'll be paying dividends to distribute the post tax reserves. I've been reading up on PCRT and wonder whether we're still allowed to suggest that the dividends are made over 3 tax years, so as to avoid any of the shareholders going over £100k (to avoid high marginal tax rate etc) and so at least some of the dividends falls into basic rate band for each of the years. My worry is, though, is that there's no reason for doing that other than tax planning/reduction. Would deliberately spreading over 3 years be caught by the PCRT wording of "highly artificial or highly contrived" or indeed caught it be caught by the older GAAR? Or am I over-thinking this and spreading dividends over tax years would fall within allowed "normal" tax planning?
19th Feb 2021
Is this normal tax planning allowed under the new
Under the new PCRT, is it still allowed to split dividends between tax years where there's no reason
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