[2016] EWCA Civ 468

Court of Appeal (Civil Division)

Arden LJ, Jackson LJ, Kitchin LJ

Judgment delivered 20 May 2016

Corporation tax – Double taxation relief – Share subscription by overseas subsidiary in UK subsidiary – Shares almost immediately cancelled by reduction in capital – Resulting reserve paid by way of dividend to overseas subsidiary – Onward dividend to UK parent – Income and Corporation Taxes Act 1988 (‘ICTA 1988’), s. 18 (Sch. D, Case V) and (Double Taxation Relief), Pt. XVIII – Whether ‘underlying tax’ arose to which ICTA 1988, s. 801(4B) applied.

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