Mr THK Everett and Dr AN Brice.

Decision released 22 November 1995.

Corporation tax – Residence of companies – UK Parent company resident in UK – Whether subsidiaries managed outside UK which adopted group policy were also resident in UK – Parent did not control the boards of the subsidiaries in the exercise of their powers although it could have taken steps to remove directors – Group policy was to devolve decision making to subsidiaries – Subsidiaries were not resident outside UK – Appeal allowed.

Graham Aaronson QC and Joseph Hage, counsel instructed by Price Waterhouse, chartered accountants for the companies.

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