The European Court of Justice’s (ECJ) second judgment in the Franked Investment Income Group Litigation (FII GLO) clarifies when EU taxpayers can rely on free movement of capital for outward investments into non-EU jurisdictions. It also highlights the need for an answer regarding inward investment from non-EU taxpayers.
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The OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year