Share buyback taxation: characterisation as dividend or capital gain shapes interim security measures to protect tax recovery.

Whether consideration paid by a company for purchase of its own shares should be treated as a dividend or as capital gain was contested, focusing on the interaction between the additional tax on distributed income and the special capital gains regime for buybacks; the court identified substantial questions of law about the tribunal's classification and ordered provisional financial security measures - partial deposit and property security - with conditional release of liens upon compliance.

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