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Beyond Credit

 
Liesl Fichardt Partner Dorsey & Whitney Chris Morgan Head of International Corporate Tax KPMG and Alastair Munro Director International Corporate Tax KPMG bring us the second article on FII GLO
 
The final decision in the FII GLO case has been eagerly awaited by UK multinationals as it goes to the heart of two fundamental aspects of the UK's corporation tax rules: the very complex credit system of taxation for foreign dividend income which has existed since the early half of the 20th century and the now defunct advance corporation tax (ACT) and foreign income dividend (FID) rules.
 
In the run-up to the decision there was much speculation that it might spell the end for the double tax relief...

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