Michael Anderson and Samantha Wilson examine the recent High Court ruling on Prudential, the test case in the CFC and dividend GLO.
Prudential is a test case in the CFC and dividend group litigation order representing a class of taxpayers who have brought claims in the High Court in respect of taxation of dividends from foreign portfolio shareholdings (i.e. holdings of less than 10%). Prior to a change in the law introduced from 1 July 2009 such dividends were taxed as Schedule D Case V income whilst dividends received from UK resident companies were exempt from corporation tax by virtue of ICTA 1988 s 208.
Many of the companies in the relevant class in the GLO are...
