In The Applicants in the Post Prudential Closure Notice Applications Group Litigation v HMRC [2021] UKFTT 459 (TC) (24 November 2021) the FTT considered eight test cases that dealt with a series of issues arising from HMRC’s approach to the recovery of tax paid on portfolio dividends (following the Supreme Court’s decision in Prudential Assurance Co Ltd). The issues before the FTT fell into five broad categories: validity of claims; time limits of claims amendments to returns; management expenses; and factual disputes with the FTT finding in favour of the taxpayers in respect of most of the issues arising under each of these categories. An indication of its complexity is that the decision runs to 230 paragraphs: the paragraph which states the tribunal’s conclusions itself runs to 48 sub-sections. Few people other than those closely involved in these issues will...
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In The Applicants in the Post Prudential Closure Notice Applications Group Litigation v HMRC [2021] UKFTT 459 (TC) (24 November 2021) the FTT considered eight test cases that dealt with a series of issues arising from HMRC’s approach to the recovery of tax paid on portfolio dividends (following the Supreme Court’s decision in Prudential Assurance Co Ltd). The issues before the FTT fell into five broad categories: validity of claims; time limits of claims amendments to returns; management expenses; and factual disputes with the FTT finding in favour of the taxpayers in respect of most of the issues arising under each of these categories. An indication of its complexity is that the decision runs to 230 paragraphs: the paragraph which states the tribunal’s conclusions itself runs to 48 sub-sections. Few people other than those closely involved in these issues will...
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