Queen’s Bench Division (Crown Office List).

[A reference to the ECJ from this decision is reported at [1988] BTC 422.]

Judgment delivered 6 February 1987.

Judicial review – Company – Transfer of residence abroad – Company wished to transfer residence to Netherlands – Revenue opposed to transfer – Whether EEC Treaty entitled company to cease to be resident in UK without Treasury consent – Whether matter should be referred to European Court – Income and Corporation Taxes Act 1970, sec. 482; EEC Treaty, Art. 52.

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