Michael Anderson and Joseph Irwin (Joseph Hage Aaronson) examine the recent High Court judgment that found largely in favour of HMRC.
On 20 February 2019 the High Court delivered its judgment in The Claimants Listed in Class 8 of the Group Register of the CFC & Dividend GLO v HMRC [2019] EWHC 338 (Ch) the latest decision in the controlled foreign company (CFC) and dividend group litigation order (GLO). The GLO established in 2003 concerns the tax treatment of UK resident companies that received dividends from overseas portfolio shareholdings (i.e. where the investor holds less than 10% of the voting power in the company).
The main purpose of the decision was to resolve a number of issues affecting certain follower claimants in the GLO namely those listed in ‘Class 8’. The distinguishing feature of the Class 8 claimants is that their claims were all issued after March 2010....
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Michael Anderson and Joseph Irwin (Joseph Hage Aaronson) examine the recent High Court judgment that found largely in favour of HMRC.
On 20 February 2019 the High Court delivered its judgment in The Claimants Listed in Class 8 of the Group Register of the CFC & Dividend GLO v HMRC [2019] EWHC 338 (Ch) the latest decision in the controlled foreign company (CFC) and dividend group litigation order (GLO). The GLO established in 2003 concerns the tax treatment of UK resident companies that received dividends from overseas portfolio shareholdings (i.e. where the investor holds less than 10% of the voting power in the company).
The main purpose of the decision was to resolve a number of issues affecting certain follower claimants in the GLO namely those listed in ‘Class 8’. The distinguishing feature of the Class 8 claimants is that their claims were all issued after March 2010....
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