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The FII group litigation: the end of the beginning or the beginning of the end?

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The Supreme Court has handed down its third judgment in the Test Claimants in the Franked Investment Income Group Litigation v HMRC [2021] UKSC 31, which concerns the tax treatment of dividends received by UK resident companies from their non-UK resident subsidiaries. In its latest judgment, the Supreme Court determined, inter alia, a number of issues as a matter of principle relating to issue of liability and quantification of claims, which it is to be hoped will allow for settlement of these long running claims. Given the sums involved however, and if history is any guide to the future, litigation may well ensue because, for example, FNR DTR credit could be available for third-country dividends received after 31 March 2001.

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