FII-GLO

High Court considers FII GLO limitation period.

Ben Webster, James Drake-Linney, Leyla Garahan

Ben Webster, James Drake-Linney and Leyla Garahan (Macfarlanes) consider the change in approach to limitation periods for overpayment claims and the practical issues that claimants are now likely to encounter.

Simon Whitehead

Peter Stewart

Simon Whitehead and Peter Stewart (Joseph Hage Aaronson) review the recent decision in Six Continents, which considers what foreign profits should receive credit at the foreign nominal rate following an earlier ruling of the CJEU in the FII group litigation.

Chris Morgan

Chris Morgan (KPMG) provides a review of recent global developments, including: the diverted profits tax; updates from the OECD; the FII GLO High Court decision; ECOFIN, and tax news from Japan, Brazil, Norway and Luxembourg.

Simon Whitehead

Simon Whitehead (Joseph Hage Aaronson) examines the High Court judgment in the FII GLO handed down on 18 December.

Peter Cussons

Peter Cussons reviews the latest instalment in the long-running FII GLO saga

The CJEU issued its judgment following third preliminary reference in the franked investment income group litigation order (FII GLO) on 12 December 2013.

Chris Morgan

Chris Morgan provides an overview of recent developments, including the CJEU decision in the FII GLO, the measures announced in the Autumn Statement to tackle tax avoidance and evasion, proposed amendments to the Parent-Subsidiary Directive and updates from France, Spain and Germany.

Chris Morgan

The monthly review by Chris Morgan examines two important developments in the EU, and the contrasting approaches to tax reform taken by Argentina and Portugal.

Simon Whitehead

Simon Whitehead ponders the advocate general’s opinion in the FII Test Claimants case

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