HMRC v The Applicants/Appellants in the Post-Prudential Closure Notice Application Group Litigation/ Appeals Group Litigation

Upper Tribunal Tax and Chancery decision of MR JUSTICE RICHARD SMITH and JUDGE JONATHAN CANNAN on 25 January 2024

Read Full Decision in HMRC v The Applicants/Appellants in the Post-Prudential Closure Notice Application Group Litigation/ Appeals Group Litigation

Corporation tax – double taxation relief on foreign dividend income – portfolio holdings – procedural issues arising out of claims for relief and claims for repayment of overpaid tax following the UK’s established breach of EU law

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Published 25 January 2024