[2006] EWHC 117 (Ch).

Chancery Division.

[The appeal against this decision is reported at [2007] BTC 285.]

Etherton J.

Judgment delivered 7 February 2006.

Corporation tax – Tax credit – Double tax agreement – Non-discrimination – Whether UK permanent establishment of Swiss company entitled to payment of tax credit on dividends – Whether right to tax credits incorporated into UK law – Income and Corporation Taxes Act 1988, s. 243, 788(3)(a), (d) – UK-Switzerland Double Taxation Convention 1977 – Double Taxation Relief (Taxes on Income) (Switzerland) Order 1978 (SI 1978/1408).

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