The Test Claimants in the FII Group Litigation v HMRC

In The Test Claimants in the FII Group Litigation v HMRC [2014] EWHC 4302 (18 December 2014) the High Court (Henderson J) handed down its decision on the quantum and related issues in the FII GLO.

This is the latest instalment of a judicial saga which started in June 2004 when Park J referred the case to the then ECJ. Since then there have been several more references to the CJEU and two other cases – Prudential [2013] EWHC 3249 and Littlewoods [2014] EWHC 868 – also have a bearing on the final outcome.

In his introduction to the case Henderson J explains: ‘Because of the general importance of nearly all the issues the status of the claims as test cases in group litigation the practical certainty of appeals whatever I decide and the huge amounts of money at stake I have...