Tax statute is not discriminatory
Boake Allen Ltd. v. Revenue and Customs Commissioners
House of Lords
“Section 247 of the Income and Corporation Taxes Act 1988, by denying companies with foreign parents the right to make a group income election allowing a subsidiary company to pay dividends to a parent company free of advance corporation tax, did not infringe the nondiscrimination articles of the double taxation agreements between the United Kingdom and the United States, or between the UK and Japan.”
The Times, 24th May 2007
Source: www.timesonline.co.uk
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