“The United Kingdom tax authorities had not assumed responsibility for eliminating double taxation on the dividend paid by a UK subsidiary to a parent resident in the Netherlands or Italy in circumstances where the UK had not levied corporation tax on the dividend.”
WLR Daily, 15th February 2008
Source: www.lawreports.co.uk
Please note once a case has been fully reported in one of the ICLR series the corresponding WLR Daily summary is removed.