Imperial Chemical Industries Plc v Colmer (No 2)

Subject Matter

REVENUE — Corporation tax — Group relief — Consortium relief — Company's business of holding shares in subsidiary companies — 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, s 258(5)(b)(7) — EC Treaty, arts 5, 52, 58

[1999] 1 WLR 2035; [2000] 1 All ER 129; [1999] STC 1089; 72 TC 1; [2000] 1 CMLR 142, HL(E)