Rupert Shiers and Kit Dickson simplify the complex decision in Test Claimants in the FII GLO, and explain 'what next' for EU claims and High Court claims in particular
On 6 April 1999 the UK's partial imputation regime was abolished. Test Claimants in the Franked Investment Income Group Litigation v HMRC [2010] EWCA Civ 103 deals with issues arising from that regime and with the taxation of foreign dividends. In a decision on 23 February 2010 the Court of Appeal decided that further questions would have to be referred back to the ECJ. This means that even now taxpayers affected by this decision are still at least three years (and probably much more) away from finality.
Fifteen months ago we reported on the lengthy decision in this case of Henderson J in the High Court. We said that it was a model of simplicity and clarity. The Court...
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Rupert Shiers and Kit Dickson simplify the complex decision in Test Claimants in the FII GLO, and explain 'what next' for EU claims and High Court claims in particular
On 6 April 1999 the UK's partial imputation regime was abolished. Test Claimants in the Franked Investment Income Group Litigation v HMRC [2010] EWCA Civ 103 deals with issues arising from that regime and with the taxation of foreign dividends. In a decision on 23 February 2010 the Court of Appeal decided that further questions would have to be referred back to the ECJ. This means that even now taxpayers affected by this decision are still at least three years (and probably much more) away from finality.
Fifteen months ago we reported on the lengthy decision in this case of Henderson J in the High Court. We said that it was a model of simplicity and clarity. The Court...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
