Chancery Division.

[The appeal against this decision is reported at [1988] BTC 3.]

Judgment delivered 14 March 1986.

Corporation tax – Advance corporation tax – Double tax relief – Credit for foreign tax – Whether double tax relief should be allowed as a credit before any set-off of ACT – Whether company had discretion to make allocation of ACT which it had paid – Income and Corporation Taxes Act 1970, sec. 501; Finance Act 1972; sec. 100(6).

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