Rupert Shiers, Partner, McGrigors, and Jonathan Bridges, Associate Partner, KPMG, take us through the franked investment income group litigation
Rupert Shiers Partner McGrigors and Jonathan Bridges Associate Partner KPMG take us through the franked investment income group litigation
The decision of the High Court in Test Claimants in the Franked Investment Income GLO [2008] EWHC 2893 (Ch) comes almost two years after the ECJ's decision in that case. The ECJ had held (C-446/04) that the UK's tax regime for foreign dividends and the rules which gave rise to substantial surplus ACT for UK multinationals were in principle contrary to EC law.
HMRC has kept these claims in limbo ever since and this is the first guidance from the domestic courts on how...
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Rupert Shiers, Partner, McGrigors, and Jonathan Bridges, Associate Partner, KPMG, take us through the franked investment income group litigation
Rupert Shiers Partner McGrigors and Jonathan Bridges Associate Partner KPMG take us through the franked investment income group litigation
The decision of the High Court in Test Claimants in the Franked Investment Income GLO [2008] EWHC 2893 (Ch) comes almost two years after the ECJ's decision in that case. The ECJ had held (C-446/04) that the UK's tax regime for foreign dividends and the rules which gave rise to substantial surplus ACT for UK multinationals were in principle contrary to EC law.
HMRC has kept these claims in limbo ever since and this is the first guidance from the domestic courts on how...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
