Chancery Division.

[The appeal against this decision is reported at [1993] BTC 398.]

Millett J.

Judgment delivered 5 December 1991.

Corporation tax – Consortium relief – Meaning of ‘holding company’ – Relief claimed for losses of UK trading subsidiary of UK holding company owned as to 49 per cent by claimant – Holding company was 90 per cent owner of 23 companies, four of which resident in UK – Whether conditions for consortium relief satisfied – Income and Corporation Taxes Act 1970, sec. 258(2), (5)(b), (7) (replaced by sec. 402(3), 413(3)(b), (5) of the 1988 Act).

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