Justice Henderson delivers FII Group Litigation judgment on quantification issues for subsidiary dividend taxation

January 13 2015

The latest judgment in the Franked Investment Income (FII) GLO, handed down by Justice Henderson in the High Court in London on December 18 2014, deals with the quantification of the test claimants’ claims and follows on from liability hearings in the High Court, the Court of Appeal, the Supreme Court and three references to the European Court of Justice (ECJ).

Unlock this content.

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

To unlock this content:

Request Access or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

Unpacking HMRC’s approach to the pillar two side-by-side package

The UK has confirmed its approach to the OECD’s side-by-side deal, but US-parented groups may find pillar two compliance remains far from straightforward

Lauren Smyth, August 12 2026

Direct Tax

Multinationals brace for more tax disputes: Baker McKenzie survey

Fragmented pillar two taxation and increased use of AI by tax authorities have left clients fearful of heightened disputes exposure

Antonia Maria Azpeitia , August 11 2026

Direct Tax

Beyond the headlines: Why Grant Thornton’s CBIZ deal won’t create a ‘big five’

Grant Thornton Advisors’ latest acquisition has produced the fifth-largest US advisory firm by revenue, but there’s still a clear gulf between it and the big four

Tom Baker, August 10 2026

Direct Tax

Crowe secures private equity investment from KKR

Crowe joins Grant Thornton, WTS and Ryan in attracting PE investment, suggesting that dealmakers remain bullish on the tax advisory sector

Sam Sholli, August 10 2026

Direct Tax

A taxing week: HMRC's audit woes will rightly fuel tax adviser concerns

HMRC expects advisers to meet ever-higher compliance criteria. After 24 consecutive qualified audit opinions, many will ask whether HMRC should hold itself to the same standards

Sam Sholli, August 07 2026

Indirect Tax

Wolters Kluwer acquires tax automation provider for €112m

The purchase of Marosa represents the second major tax tech consolidation this week, raising questions of a broader industry trend

Sam Sholli, August 06 2026

Transfer Pricing

TP in Peru: where global profitability policies meet a transaction-by-transaction regime

Peru’s approach to TP is increasingly at odds with OECD-style profitability policies, exposing multinational groups to asymmetric tax adjustments

Miguel Puga, August 06 2026

Direct Tax

How ESR and pillar two are converging across the GCC

Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test

Hany Elnaggar, August 05 2026

Transfer Pricing

Alphatax broadens TP portfolio with double acquisition

The deals for TP Accurate and Intra Pricing Solutions will enhance Alphatax’s ability to support clients with the full TP lifecycle, the tax tech provider claimed

Sam Sholli, August 04 2026

Indirect Tax

From advisory to advocacy: why Gunjan Prabhakaran chose litigation

The DS Advocates partner discusses career reinvention, tax disputes and why advisory and litigation experience should complement one another

Tom Baker, August 04 2026