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 .
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.
Published 1 December 2016