A ‘Holding company’ under the Act meant a company resident in the UK; A reference was made of the issues to the European Court.
Citations:
Times 15-Mar-1996
Statutes:
Income and Corporation Taxes Act 1970 285(5)(b)
Citing:
Appeal from – Imperial Chemical Industries v Colmer (Inspector of Taxes) CA 9-Aug-1993
Group tax relief was available despite other subsidiary companies within the same group being offshore. . .
Cited by:
Reference from – Imperial Chemical Industries v Colmer ECJ 16-Jul-1998
A member state was not allowed to impose a tax regime which discriminated against the subsidiaries of a company based in that state where they were based in other member states, but discrimination was allowed where the subsidiaries were based . .
Reference from – Metallgesellschaft Ltd and Others v Inland Revenue Commissioners and Another Hoechst Ag and Another v Same ECJ 8-Mar-2001
The British law which meant that non-resident parent companies of British based businesses were not able to recover interest on payments of advance corporation tax, was discriminatory against other European based companies. Accordingly the law was . .
See Also – Pickford v Imperial Chemical Industries Plc HL 30-Jun-1998
In the absence of conclusive evidence establishing a cause of a condition, the judge was free to find that causation was not established and that the claim was lost. There was no necessary obligation on an employer to have procedures which might . .
Lists of cited by and citing cases may be incomplete.
Company
Updated: 08 April 2022; Ref: scu.81593
