Court of Appeal (Civil Division).

Lord Woolf MR, Peter Gibson and Brooke LJJ.

Judgment delivered 21 December 1998.

Corporation tax – Double taxation relief – Charges on income – Interest – Whether charges on income had to be fully utilised before double taxation relief applied – Income and Corporation Taxes Act 1988, s. 338(1), 393(9), 797(3).

  This was an appeal by the taxpayer (‘CU’) against a judgment of Harman J ( [1998] BTC 89) that a company had to deduct charges on income from its profits before giving credit for double taxation relief (‘DTR’).

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