Chancery Division.

[The appeal against this decision is reported at [1999] BTC 12.]

Harman J.

Judgment delivered 20 February 1998.

Corporation tax – Double taxation relief – Charges on income – Interest – Foreign tax paid by subsidiaries – Extent to which foreign tax could be allocated to profits of group as a whole – Whether interest payments were made ‘wholly and exclusively’ for the purposes of the trade of the taxpayer – Income and Corporation Taxes Act 1988, s. 393(9), 797(3).

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