Peninsular and Oriental Steam Navigation Company v The Commissioners for HM Revenue and Customs: [2015] UKUT 0312 (TCC)
Upper Tribunal Tax and Chancery decision of Mrs Justice Proudman and Judge Bishopp on 19 June 2015.
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CORPORATION TAX 鈥� double taxation relief 鈥� dividend paid to related company 鈥� share subscription by overseas company in UK subsidiary 鈥� shares almost immediately cancelled with reduction of capital 鈥� subscription money credited to reserves 鈥� reserves then paid by way of dividend to overseas company 鈥� no UK tax borne by reserves 鈥� onward dividend paid to UK holding company 鈥� liability for Case V tax 鈥� whether ICTA s 801(4B) to be applied to 鈥渦nderlying tax鈥� 鈥� no 鈥� appeal dismissed.
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Published 1 December 2016