The case of Test Claimants in the FII Group Litigation v HMRC is to be referred to the ECJ for the second time on the grounds that a significant part of the original ECJ judgment was insufficiently clear. This is probably not surprising since ECJ decisions in tax cases are sometimes notorious for their opacity (which is why Tax Journal summaries tend to quote directly from the concluding part of the judgment rather than seek to paraphrase them). HMRC have gained a partial victory with regard to the principles of restitution and the appropriate limitation periods.
Business Tax
Corporation tax:...
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The case of Test Claimants in the FII Group Litigation v HMRC is to be referred to the ECJ for the second time on the grounds that a significant part of the original ECJ judgment was insufficiently clear. This is probably not surprising since ECJ decisions in tax cases are sometimes notorious for their opacity (which is why Tax Journal summaries tend to quote directly from the concluding part of the judgment rather than seek to paraphrase them). HMRC have gained a partial victory with regard to the principles of restitution and the appropriate limitation periods.
Business Tax
Corporation tax:...
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