Ordinary share capital: can a negative prove a positive? | Practical Law
In a recent decision, the First-tier Tribunal addressed whether shares with no dividend rights can be said to carry a fixed rate of dividend and therefore not be treated as ordinary share capital for the purposes of entrepreneurs’ relief. In deciding that they did carry a fixed rate, the tribunal took a position that departs from both HM Revenue & Customs and market practice, and seemingly contradicts another recent tribunal decision.