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