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Investments Outside the EU

Simon Whitehead partner Dorsey & Whitney London reviews an uncertain state of affairs
Come 1 April 2010 FA 2009 Sch 52 will take effect ostensibly shutting the door on many ways in which overpaid corporation tax can currently be recovered. The new statutory regime appears intended to prohibit the broader forms of relief available through High Court claims and impose a four-year time limit where currently in many circumstances claims can stretch back decades. Now might therefore be thought the season to ensure that any such claims which should be made have been made. With that purpose in mind this article attempts to summarise where claims currently stand in one area of constant development: the imposition of corporation tax upon dividend income received from beyond the...

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