Chancery Division.

[The appeal against this decision is reported at [1990] BTC 253.]

Judgment delivered 31 August 1988.

Double taxation relief – Distribution by UK subsidiary to US corporation – Tax credit entitlement – Payment for tax credits by UK Government – Five per cent deduction from payment – Whether deduction from payment authorised – If deduction authorised what method of calculation should be adopted – Income and Corporation Taxes Act 1970, sec. 497(1)(d)Finance Act 1972, sec. 86 – Double Taxation Relief (Taxes on Income) (The United States of America) Order 1980 (S.I. 1980 No. 568), art. 10(2)(a)(i).

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