The High Court hearing concluded on 19 July. The hearing dealt with issues arising out of corporation tax charges on foreign-source portfolio dividends, ACT charges on their onward payment and a number of issues specific to life assurance and pension business, as well as remedies, including the availability of compound interest, and HMRC’s contention that unlawful tax paid under a mistake could not be recovered where the UK had applied its tax revenues against government expenditure (“the change of position” defence). Judgment has been reserved.
Similar issues will be considered in the context of dividends from subsidiaries at the hearing of the FII GLO, which is listed for 29 April 2014.
This article appears in the JHA July 2013 Tax Newsletter, which also features:
