Court of Appeal.

[The appeal against this decision is reported at [1989] BTC 167.]

Judgment delivered 25 November 1987.

Corporation tax – Advance corporation tax – Double tax relief – Credit for foreign tax – Whether double tax relief should be allowed as credit before set-off of advance corporation tax – Whether company had discretion to make allocation of advance corporation tax paid – Income and Corporation Taxes Act 1970. sec. 497(1), 501, 505; Finance Act 1972, sec. 85(1), 100(3)-(6).

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