Chris Morgan reviews recent developments, including the recent CFC and dividend group litigation (Prudential Assurance Company Ltd), the AG’s opinion in Felixstowe and Emerging Market Series, and updates to tax rules in Brazil, Ireland and Norway.
Since I wrote my last article the High Court has published its decision in that part of the CFC and dividend group litigation that relates to portfolio dividends where the test claimants were from the Prudential Assurance group (The Prudential Assurance Company Ltd & Anor v HMRC [2013] EWHC 3249).
The key point in this case relates to the taxation of portfolio dividends (i.e. holdings of less than 10%) under the old Schedule D Case V rules in ICTA 1988 whereby double tax relief was given for foreign withholding taxes paid on the dividends but not for...
