Test Claimants in the FII Group Litigation v Commissioners of Inland Revenue and Another: ECJ 13 Nov 2012

Articles 49 TFEU and 63 TFEU – Payment of dividends – Corporation tax – Case C-446/04 – Test Claimants in the FII Group Litigation – Interpretation of the judgment – Prevention of economic double taxation – Equivalence of the exemption and imputation methods – Meaning of ‘tax rates’ and ‘different levels of taxation’- Dividends from third countries
[2012] WLR(D) 323, [2013] 1 CH 431, [2013] 2 WLR 1416, ECLI:EU:C:2012:707, [2013] 1 CMLR 50, [2012] EUECJ C-35/11, [2012] STI 3271, [2013] STC 612, [2013] BTC 424
WLRD, Bailii
Cited by:
CitedPrudential Assurance Company Ltd v Revenue and Customs SC 25-Jul-2018
PAC sought to recover excess advance corporation tax paid under a UK system contrary to EU law. It was now agreed that some was repayable but now the quantum. Five issues separated the parties.
Issue I: does EU law require the tax credit to be . .

Lists of cited by and citing cases may be incomplete.
Updated: 10 August 2021; Ref: scu.666510