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).
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
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