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

Transfer Pricing

Experts question whether UK TP proposal is ‘absolutely necessary’

The Institute of Chartered Accountants in England and Wales also queried whether HMRC resources could be better spent scrutinising larger entities

Sam Sholli, July 09 2025

Transfer Pricing

‘Coffee is the only constant’: Raphael Holzinger on the pressures of his practice

Grant Thornton’s Austria tax head likens his practice to an escape room, shares his football coaching ambitions, and explains why tax is cool

July 09 2025

Awards

ITR EMEA Tax Awards 2025: shortlist announced

ITR is delighted to reveal all the shortlisted nominees for the 2025 EMEA Tax Awards

John Harrison, July 08 2025

Awards

ITR APAC Tax Awards 2025: shortlist announced

ITR is delighted to reveal all the shortlisted nominees for the 2025 Asia-Pacific Tax Awards

John Harrison, July 08 2025

Direct Tax

Opinion: G7’s pillar two capitulation proves US power always wins

The fates of pillars one and two hang in the balance after the US successfully threw its weight around in G7 and Canadian negotiations

Tom Baker, July 07 2025

Direct Tax

Mexican tax firm founder ‘won’t sacrifice quality for size’

Rafael Tena tells ITR about the ‘crazy’ Mexican market, ditching the hourly rate, and refusing to grow his fledgling firm in an ‘unstructured way’

Tom Baker, July 07 2025

Direct Tax

UK tax adviser ‘shocked’ at in-house costs criticism

It should be easy for advisers to be transparent about costs, Brown Rudnick partner Matthew Sharp said in response to exclusive ITR in-house data

Tom Baker, July 04 2025

Direct Tax

This week in tax: Donald Trump’s ‘big beautiful’ tax bill narrowly gets through Congress

The sprawling legislation phases out Joe Biden-era green tax incentives for businesses; in other news, the UK will reportedly maintain its DST despite US pressure

Sam Sholli, July 04 2025

Direct Tax

French Finance Act 2025: Major tax reform for management packages

New French legislation should create a more consistent legal environment for taxing gains from management packages, say Bruno Knadjian and Sylvain Piémont of Herbert Smith Freehills Kramer

Bruno Knadjian , July 03 2025

Transfer Pricing

‘TP litigation here to stay’: experts dissect South Africa ruling

The South Africa vs SC ruling may embolden the tax authority to take a more aggressive approach to TP assessments, an adviser tells ITR

Sam Sholli, July 02 2025