Special Commissioners of Income Tax 25 January 2000, SPC00231 (Océ Van Der Grinten Nv v The Commissioners of Inland Revenue)

DOUBLE TAXATION - Relief - EC "Parent-Subsidiary" Directive - Dividends paid by UK corporation to Netherlands parent corporation - Tax credit abated by 5% of the aggregate of dividend and tax credit by operation of Double Taxation Treaty - EC Directive requires profits distributed to parent company by subsidiary to be exempt from withholding tax - Whether exemption extends to 5% abatement -