Advocate General opinion in FII GLO encourages claimants

September 30 2013

The Franked Investment Income Group Litigation (FII GLO) concerning claimants' rights to recover overcharged tax from HM Revenue & Customs (HMRC) has been batted back and forth between the UK courts and the European Court of Justice (ECJ) since 2006. Philippe Freund, of Joseph Hage Aaronson, explains why an Advocate General's opinion on the third reference to the ECJ has given taxpayers cause to be optimistic.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

New Indian ruling on applying multilateral instruments and PPT provisions: analysis

Authors from Khaitan & Co dissect a ‘welcome’ ruling, which found that the mere existence of a tax benefit would not, by itself, warrant a principal purpose test

Sanjay Sanghvi, September 16 2025

Direct Tax

Big Ben and the Houses of Parliament at night in London, UK

Three-quarters of UK public support PCbCR: report

Over two-thirds of survey respondents back the continuation of the UK’s digital services tax, research commissioned by the Fair Tax Foundation also found

Tom Baker, September 15 2025

Direct Tax

A taxing week: The OECD must take developing countries seriously

Given the US/G7 pillar two deal, the OECD is in danger of being replaced by the UN as the leading global tax reform forum

Sam Sholli, September 12 2025

Direct Tax

This week in tax: PE house Cinven invests in Grant Thornton Germany

Cinven’s latest investment follows its acquisition of a stake in Grant Thornton UK in December; in other news, a barrister listed by HMRC as a tax avoidance promoter has alleged harassment

Tom Baker, September 12 2025

Direct Tax

Corporate income tax rate reductions slowing down: OECD report

CIT base narrowing measures remain more prevalent than increased CIT rates, the report also highlighted

Sam Sholli, September 11 2025

Direct Tax

Legal Benchmarking Group acquires The Lawyer

ITR's parent company, LBG, will acquire The Lawyer, a leading news, intelligence and data-driven insight provider for the legal industry, from Centaur Media

Ed Conlon, September 11 2025

Transfer Pricing

Multilateral APAs in the UK and Netherlands: a history

KPMG UK’s Graeme Webster and KPMG Meijburg & Co’s Eduard Sporken outline the 20-year evolution of MAPAs, with DEMPE analyses becoming more prevalent and MAPA requirements growing stricter

Graeme Webster, September 11 2025

Direct Tax

Telecommunication tower Antenna at sunset sky.

Input tax credit eligibility for telecom towers: Indian case law analysis

Rishi Joshi, of the Institute of Chartered Accountants of India, warns of potential judicial overreach as assets are recharacterised to bypass a legislative exclusion

Rishi Joshi, September 10 2025

Transfer Pricing

TP costs rocket for MNEs, report reveals

Only 2% of in-house survey respondents said they were ‘heavy’ users of AI for TP, Aibidia’s report also found

Tom Baker, September 09 2025

Direct Tax

Oslo, Norway - 24 September 2022: PricewaterhouseCoopers or PWC

Ex-PwC Australia CEO Thomas Seymour deregistered over tax scandal role

There was a ‘deeply embedded culture within PwC that routinely disregarded formal confidentiality obligations,’ the chairman of Australia’s Tax Practitioners Board said

Sam Sholli, September 09 2025