High Court clarifies test claimant’s entitlement to recover compound interest in CFC and dividend GLO

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement


High Court clarifies test claimant’s entitlement to recover compound interest in CFC and dividend GLO

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.

To unlock this content:

Request Access or Login
more across site & shared bottom lb ros

More from across our site

Boaz Goren’s move to the upstart PE-backed firm takes the number of senior UK tax professionals who have left EY this year to 13
The allegations against Deloitte Cyprus raise uncomfortable questions about how far the big four can distance themselves from misconduct at member firms
The UAE accounted for most Middle East promotions and new rankings, as A&M Tax, Baker McKenzie, Dhruva Consultants and DLA Piper breached the top tier
Spanish-headquartered multinationals lead on reporting quality, while US and Swiss groups lag in the Fair Tax Foundation’s expanded analysis
Former IRS commissioner Danny Werfel joins ITR for a must-listen conversation spanning his time leading the agency, his AI risk framework, and the future of the OECD
Tax and legal services was PwC’s fastest-growing business line last year, helping to put the firm back on a par with its big four rivals
Ex-EY and Hourani & Partners leader Zain Satardien is using flexible staffing and AI-enabled systems to test a leaner model for specialist legal and tax advice
The big four firm is rightfully prioritising transparency and accountability as it seeks to rebuild from its scandal, but a glaring structural issue remains
A recent hiring flurry has taken the firm’s number of partner appointments this year to 121 and put it on track to hit 160 partner target early
The move brings specialist tax and litigation capability to EY as it seeks to close the gap on Baker McKenzie and Venezuela’s leading local firms
Gift this article