45In the context of a tax rule which seeks to prevent or to mitigate the taxation of distributed profits, the situation of a parent company receiving foreign-sourced dividends is comparable to that of a parent company receiving nationally-sourced dividends in so far as, in each case, the profits made are, in principle, liable to be subject to a series of charges to tax (see Test Claimants in the FII Group Litigation, paragraph 62).
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