CORPORATION TAX – double taxation relief – dividend paid to related company – share subscription by overseas company in UK subsidiary – shares almost immediately cancelled with reduction of capital – subscription money credited to reserves – reserves then paid by way of dividend to overseas company – no UK tax borne by reserves – onward dividend paid to UK holding company – liability for Case V tax – whether ICTA s 801(4B) to be applied to ‘underlying tax’ – no – appeal dismissed
[2015] UKUT 312 (TCC), [2015] STC 2393, [2015] BTC 520, [2015] STI 2027
Bailii
England and Wales
Corporation Tax
Updated: 19 November 2021; Ref: scu.553180