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.

Read the full decision in Peninsular and Oriental Steam Navigation Company v The Commissioners for HM Revenue and Customs: [2015] UKUT 0312 (TCC).

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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