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No second chance

02 October 2014
Issue: 4472 / Categories: Tax cases , Companies , Europe , International , Residence & domicile

FII Group Litigation v CIR and another, Court of Appeal

The tax department wished to make amendments to their defence in the FII group litigation, which concerned the UK’s treatment of dividends received by resident companies from group subsidiaries in the EU and non-EU countries.

The Court of Appeal said, “The issue which HMRC wishes to raise has been conclusively determined against it by Henderson J and the Court of Appeal. Therefore, HMRC is estoppel per rem judicatum from raising the issue a second time.”

The Revenue’s application was dismissed.

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