Vowles v Revenue and Customs Commissioners

Income tax – Appeal. The taxpayer, who alleged that she had been in an abusive relationship and had only accepted an appointment as the director of a company because her partner had been disqualified as a director, was not liable to pay tax on dividends paid by the company because, on the facts, the dividends had not been paid to her, but to her partner, who had controlled the company. Further, because, whilst in law, she had been the shareholder of the company, she had held her share on behalf of her partner, who, in equity, had been the person entitled to receive the dividends. So held the First-tier Tribunal (Tax and Chancery Chamber) (the FTT) in allowing the taxpayer's appeal in part. Further, and among other things, the FTT, in applying s 50(6)(a) of the Taxes Management Act 1970, discharged certain amendments to the taxpayer's tax returns, which had been made by the Revenue and Customs Commissioners.

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