Judges:
Lord Justice Laws Sir Martin Nourse Lord Justice Peter Gibson
Citations:
[2003] EWCA Civ 1849, [2004] STI 49, [2004] Eu LR 459, [2004] BTC 50, [2004] STC 130
Links:
Jurisdiction:
England and Wales
Citing:
Appeal from – Pirelli Cable Holding NV and Others v Inland Revenue Commissioners ChD 22-Jan-2003
The Metallgesellschaft case had established that it was contrary to European law to withhold the right to ACT on dividends paid by a UK holding company to a non-Uk subsidiary. The Revenue claimed that that rule did not apply here because the non-Uk . .
Cited by:
Appeal from – Pirelli Cable Holding Nv and others v Inland Revenue HL 8-Feb-2006
Under s247 of the 1988 Act, a company paying dividends to a parent company need not withhold ACT. This option was not offered where either subsidiary or parent was not UK resident until the decision in Hoechst which found the restriction contrary to . .
Lists of cited by and citing cases may be incomplete.
Corporation Tax, European
Updated: 12 November 2022; Ref: scu.188913