HL 1999, 72 TC 1;  STC 1089;  1 WLR 2035;  1 ALL ER 129
Imperial Chemical Industries (ICI) owned 49% of a UK holding company with the other 51% held by a The Wellcome Foundation Ltd. The holding company had 23 subsidiaries, all but one of which were wholly-owned, but only four were UK resident companies. One of these subsidiaries made a loss and for which ICI claimed consortium relief. The Inland Revenue denied the claim to relief, contending that the company had to be the holding company of only UK resident companies.
It was held by the House of Lords that it was not necessary under ICTA 1988, s413(3) for all of the subsidiary companies to be UK resident. Consortium relief was therefore available.