The Weekly Law Reports
[1999] 1 WLR 2035
[HOUSE OF LORDS]
IMPERIAL CHEMICAL INDUSTRIES PLC. Respondents and COLMER (INSPECTOR OF TAXES) Appellant (No. 2)
1999 June 29;
Nov. 18
Nov. 18
Lord Nicholls of Birkenhead, Lord Keith of Kinkel, Lord Mustill and Lord Nolan
Revenue
— Corporation tax
— Group relief
— Consortium relief
— Company's business of holding shares in subsidiary companies
— Whether “holding company”
— Decision as matter of domestic law that subsidiary companies must be wholly or mainly resident in United Kingdom
— Whether decision in conflict with Community law where majority of subsidiary companies resident outside Community
—
Income and Corporation Taxes Act 1970 (c. 10), s. 258(5)(b)(7)
—
E.C. Treaty, arts. 5, 52, 58