A dividend is a corporation's distribution of its after-tax profits to shareholders, typically paid in cash per share, though it can also be issued as additional shares or assets. While shareholders treat dividends as taxable income, the corporation does not receive a tax deduction for them, and they are not considered an expense but a reduction of retained earnings. The Dutch East India Company (VOC) was the first public company to pay regular dividends, distributing around 18% of share value annually from 1602 to 1800. Historically, courts in common law jurisdictions have given directors wide discretion over dividend payments, as established in cases like Burland v Earle (1902), though a 2013 Australian case (Sumiseki Materials Co Ltd v Wambo Coal Pty Ltd) recognized a shareholder's contractual right to a dividend. Cash dividends are the most common form, paid per share, and preferred stocks hold priority claims over common stocks for these payments. Dividends are not guaranteed, and companies may cancel or declare special one-off dividends at any time.