The England and Wales High Court’s recent ruling on quantification in the controlled foreign company (CFC) and dividend group litigation order (GLO) clarifies that the test claimant is entitled to recover compound interest on claims for unlawful corporation tax paid both in open and closed accounting periods. However uncertainty remains about when, and by which court or tribunal, the test claimant may recover the sums due.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The US president has softened his stance on tariffs over Greenland; in other news, a partner from Osborne Clarke has won a High Court appeal against the Solicitors Regulation Authority
Hany Elnaggar examines how AI is reshaping tax administration across the Gulf Cooperation Council, transforming the taxpayer experience from periodic reporting to continuous compliance
Businesses that adopt a proactive strategy and work closely with their advisers will be in the greatest position to transform HMRC’s relief scheme into real support for growth
The flagship 2025 tax legislation has sprawling implications for multinationals, including changes to GILTI and foreign-derived intangible income. Barry Herzog of HSF Kramer assesses the impact