'[Test Claimants in the FII Group Litigation v HMRC] is an immensely complicated case and HM Treasury and HMRC will be pleased by the Court of Appeal's judgment since it limits significantly claims which may be made. The case concerns whether or not the UK's double tax relief rules for companies breached EU law. The original judgment of the ECJ was unclear on one major point [concerning dividends received in the UK from 10% or greater shareholdings in EU companies] and the Court of Appeal has decided that the ECJ must be asked for clarification. Additionally the ECJ was not originally asked to rule on more complicated group structures — and the Court of Appeal believes a referral on those issues is now needed … On remedies the Court of...
