Court of Appeal (Civil Division).

Peter Gibson and Henry LJJ and Sir Christopher Staughton.

Judgment delivered 9 June 1998.

Corporation tax – Double taxation relief – UK company received share of profits under ‘silent partnership’ agreement under German law – Whether share of profits was a ‘dividend’ – Whether company entitled to tax credit for German trade tax paid by German subsidiaries – Income and Corporation Taxes Act 1988, s. 801(1)Double Taxation Relief (Taxes on Income) (German Federal Republic) Order 1964 (SI 1967/25), art. 18(1), 6(4) (as amended by the Protocol of 23 March 1970).

Need help? Get subscribed!

To subscribe to this content, simply call 0800 231 5199

We can create a package that’s catered to your individual needs.

Or book a demo to see this product in action.