Kellogg Brown & Root Holdings Ltd v HMRC

HMRC has won the latest round in the long-running saga of Test Claimants in the ACT Group Litigation (Class 2 and Class 4) v HMRC (No 2). The Ch D has rejected the contentions put forward by Pirelli and has found in favour of HMRC holding that 'Community law has no objection to the requirement for ACT to be paid in a greater amount than the tax credit available under the double tax conventions with the Netherlands and Italy'.