The Test Claimants In The CFC and Dividend Group Litigation v Inland Revenue: ECJ 23 Apr 2008

First subparagraph of Article 104(3) of the Rules of Procedure – Freedom of establishment – Free movement of capital – Direct taxation – Corporation tax – Share dividends paid to a resident company by a non-resident company – Rules on controlled foreign companies (‘CFCs’) – Situation as regards a non-member country – Classification of claims brought against the tax authority – Liability of a Member State for breach of Community law
[2008] EUECJ C-201/05 – O, [2008] STC 1513, ECLI:EU:C:2008:239, [2008] ECR I-2875
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.666503