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
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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