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High Court rules on outstanding issues in the CFC & Dividend GLO

Speed read
On 20 February, the High Court delivered its judgment in The Claimants Listed in Class 8 of the Group Register of the CFC & Dividend GLO v HMRC [2019] EWHC 338 (Ch), finding largely in favour of HMRC. High Court claims issued after 31 March 2010 are excluded by FA1998 Sch 18 para 51(6). The judge did, however, provide interesting guidance on the requirements for a valid statutory claim for additional double tax relief. The judge also considered several issues relating to the extended period for bringing High Court claims under the Limitation Act 1980 s 32(1)(c).
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