HMRC Business Brief on Settlement of Statutory Double Tax Relief Claims Affected by the FII and CFC Dividend GLOs

29 January 2020
Author: JHA

Many of our clients have made various historical claims for repayment of tax on dividend income.  On Friday 24 January 2020 HMRC sent JHA a “business brief” outlining their approach to resolving these claims.  In summary, HMRC say they will now accept as valid claims, in-time exemption filings with open enquiries, taxable filings with DTR claimed at the ULT rate and DTR claims outside the return within the s806(1) ICTA time limits.  The above also follows for pay and file years where there is an assessment and an appeal.

Other claims are less certain.  The brief suggests returns amended on an exemption basis will be dealt with on a case-by-case basis and is entirely silent on error or mistake claims. HMRC have indicated they will contest any claim failed outside the strict statutory time limits.  Nevertheless, the brief is an encouraging development.

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