Corporation tax – Double taxation relief – Income and Corporation Taxes Act 1988 (‘ICTA 1988’), s. 18, Sch. D, case V and Pt. XVIII – Series of intra-group transactions leading to declaration of dividends by overseas subsidiaries – Whether intermediate dividends were ‘dividends’ within statutory meaning or disguised repayment of loans – Repayment of loans – Underlying tax limited to tax paid on true dividends taken to profit – Appeal dismissed.
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