Robert Venables QC and Robert Grierson (instructed by Allen & Overy) for EVC.
Double taxation – Relief – Dividends paid by United Kingdom company to Dutch company – Dutch company set up as joint venture by two companies – Whether Dutch company entitled to tax credits in respect of dividends paid – Whether Dutch company controlled by two or more connected persons – Income and Corporation Taxes Act 1988, s 839(7) – Double Taxation Relief (Taxes on Income) (Netherlands) Order 1980, SI 1980/1961, art 10(3).