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R (on the application of Newfields Developments Ltd) v Inland Revenue Commissioners [2001] UKHL TC_73_532 (23 May 2001)

R (on the application of Newfields Developments Ltd) v Inland Revenue Commissioners [2001] UKHL TC_73_532 (23 May 2001)

Corporation tax – Reliefs – Small companies relief- – Amount of relief – Restrictions on amount of relief – Restriction where company has one or more associated companies – Control of companies – Attribution to individual of rights and powers of associates – Individual associated to two sets of trustees who respectively controlled two companies – Whether the two companies associated – Whether attribution of rights and powers of associates a matter of general discretion to be exercised by Revenue only if considered appropriate to facts of the particular case – Income and Corporation Taxes Act 1988, s 13, 416 and 417.
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