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Test Claimants in the FII GLO

Rupert Shiers Partner McGrigors and Jonathan Bridges Associate Partner KPMG take us through the franked investment income group litigation
The decision of the High Court in Test Claimants in the Franked Investment Income GLO [2008] EWHC 2893 (Ch) comes almost two years after the ECJ's decision in that case. The ECJ had held (C-446/04) that the UK's tax regime for foreign dividends and the rules which gave rise to substantial surplus ACT for UK multinationals were in principle contrary to EC law.
HMRC has kept these claims in limbo ever since and this is the first guidance from the domestic courts on how the ECJ decision should be applied in practice. Henderson J's judgment while in its own way a model...

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