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.