United Kingdom Upper Tribunal (Tax and Chancery Chamber)

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You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Peninsular & Oriental Steam Navigation Co. v Revenue And Customs [2015] UKUT 312 (TCC) (19 June 2015)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2015/312.html
Cite as: [2015] UKUT 312 (TCC), [2015] STI 2027, [2015] BTC 520, [2015] STC 2393

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Peninsular & Oriental Steam Navigation Co. v Revenue And Customs [2015] UKUT 312 (TCC) (19 June 2015)

CORPORATION TAX - double taxation relief - dividend paid to related company - share subscription by overseas company in UK subsidiary - shares almost immediately cancelled with reduction of capital - subscription money credited to reserves - reserves then paid by way of dividend to overseas company - no UK tax borne by reserves - onward dividend paid to UK holding company - liability for Case V tax - whether ICTA s 801(4B) to be applied to "underlying tax" - no - appeal dismissed

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