Administrative court dismissed tax deduction claim for advance withholding tax on corporate dividend received by minority shareholder.

The Administrative Court dismissed the taxpayer's claim to deduct advance withholding tax paid on a corporate dividend received by a minority shareholder. The taxpayer argued that the advance withholding tax constituted a deductible expense under the Income Tax Act, while the tax authority contended it was a prepayment of income tax rather than a business expense. The court ruled that the advance withholding tax is not a deductible expense because it is merely an advance payment of the final income tax liability, not a cost incurred in generating the income.