An opinion from an advocate-general of the European Court of Justice went against provisions of the UK tax system one more time. In the FII (franked investment income) group litigation against the Inland Revenue, which involved BAT group companies, Leendert Geelhoed believed the UK's rules breach EU law because they exempt dividends received by UK resident companies from other UK resident companies from corporate tax, but impose tax on dividends from companies resident in other member states, even when credit has been given for double taxation. The opinion also held that the UK's system of advance corporation tax, which has already been abolished, was discriminatory. The taxpayers were represented by Dorsey & Whitney
April 30 2006