Court of Appeal (Civil Division).

Millett Otton and Beldam LJJ.

Judgment delivered 25 July 1997.

Corporation tax – Double taxation relief – Controlled foreign company in receipt of UK source interest – Whether interest received by foreign company chargeable profits to be imputed to UK parent – Whether interest excluded from chargeable profits of parent by Netherlands Double Taxation Treaty – Double Taxation Relief (Taxes on Income) (Netherlands) Order 1980 (SI 1980/1961), art. 11Income and Corporation Taxes Act 1988, s. 747(4)(a).

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