The Supreme Court has handed down its third judgment in the long-running FII GLO case. Lee Ellis and Cristiana Bulbuc (Stewarts) consider how we got here and what this means for taxpayers with unresolved issues concerning overseas dividend taxation.
On 23 July 2021 the Supreme Court handed down its third judgment in the Test Claimants in the Franked Investment Income Group Litigation v HMRC [2021] UKSC 31 (‘the FII group litigation’). Before turning to the court’s latest decision it is necessary to set it in context given the significant and at times ground-breaking decisions to date.
Background
The claims
The FII group litigation concerns the tax treatment of dividends received by UK resident companies from their non-UK resident subsidiaries as compared with the treatment of dividends paid and received within wholly UK resident groups of companies. More specifically the FII group litigation concerns now obsolete...
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The Supreme Court has handed down its third judgment in the long-running FII GLO case. Lee Ellis and Cristiana Bulbuc (Stewarts) consider how we got here and what this means for taxpayers with unresolved issues concerning overseas dividend taxation.
On 23 July 2021 the Supreme Court handed down its third judgment in the Test Claimants in the Franked Investment Income Group Litigation v HMRC [2021] UKSC 31 (‘the FII group litigation’). Before turning to the court’s latest decision it is necessary to set it in context given the significant and at times ground-breaking decisions to date.
Background
The claims
The FII group litigation concerns the tax treatment of dividends received by UK resident companies from their non-UK resident subsidiaries as compared with the treatment of dividends paid and received within wholly UK resident groups of companies. More specifically the FII group litigation concerns now obsolete...
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:
