Chancery Division.

Judgment delivered 1 March 1982.

Corporation tax – Double taxation relief – Dividend paid by US corporation resident in UK to parent corporation resident in US – Whether dividend exempt from UK tax – Double Taxation Relief (Taxes on Income) (USA) Order 1946 – Art. XV – (See now, Double Taxation Relief (Taxes on Income) (USA) Order 1966, Art. II).

  This was an appeal by the Crown from a decision of the Special Commissioners.

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