Seddon & ors v HMRC [2015] UKFTT 140

Wills & Trusts Law Reports | July/August 2015 #151

The appellants were trustees of a discretionary settlement settled in 1999. The settlement’s original assets were five £1 ordinary shares in a limited company. In 2000 the settlement received a scrip dividend of preference shares in the company. The preference shares were sold by the trustees two days after their receipt. Their value was £1,382,750. Some nine years later and a few days before the settlement’s ten year anniversary the trustees made a distribution worth £1,260,361 to certain beneficiaries.

The principal issues concerning were:

  1. 1. Whether the...