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

Dear chancellor, follow the Irish model: a path to long-term prosperity

The lessons from Ireland are clear: selective, targeted, and credible fiscal incentives can unlock supply and investment

Chris Danes, November 24 2025

Indirect Tax

‘Extinction of tax as we know it’: Nitin Agarwal’s in-house bible

The ITR in-house award winner delves into his dramatic novelisation of tax transformation, and declares that 'tax doesn’t need AI right now'

Tom Baker, November 24 2025

Direct Tax

Oslo, Norway - 24 September 2022: PricewaterhouseCoopers or PWC

A taxing week: The PwC tax leaks scandal isn’t just hurting PwC

Recent news of job cuts at EY is symptomatic of how the PwC controversy has tarnished the reputation of the entire ‘big four’

Sam Sholli, November 21 2025

Direct Tax

This week in tax: One-year pillar two safe harbour extension being considered – reports

Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires

Sam Sholli, November 21 2025

Awards

2026 Women in Business Law Americas Awards: submissions now open

Submit your nominations to this year's WIBL Americas Awards by January 23

Shailyn Tirado, November 20 2025

Direct Tax

MHA reports 17% increase in tax revenues

Recent changes in UK tax rules and cross-border requirements are generating high demand for specialist advice, according to MHA

Sam Sholli, November 20 2025

Transfer Pricing

TP in the GCC: bridging global standards and regional implementation

Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences

Hany Elnaggar, November 20 2025

Transfer Pricing

‘Median likely best’: HMRC updates TP manual

Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default

Sam Sholli, November 19 2025

Direct Tax

EY cuts staff following PwC tax scandal-related revenue decrease: reports

EY, KPMG, Deloitte, and PwC have all seen a decrease in public sector contracts since the scandal – it is understood

Sam Sholli, November 19 2025

Direct Tax

Keeping up with Brazil’s rapid tax evolution with Breno Consoli

Consoli, a tax partner at Brazilian law firm Martinelli Advogados, tells ITR about the importance of staying at the coalface and constantly learning

November 19 2025