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In a decision of 23 May 2007, in the case of Boake Allen Ltd v HMRC,
the House of Lords (the highest Court in the U.K.) rejected the claims
in a test case under a Group Litigation Order (a kind of class action in
the U.K.) that U.K. subsidiaries of parent companies resident in non-EU
countries should be entitled to compensation where they were required
to pay advance corporation tax (ACT) on dividends paid to their parent
company because they were excluded from the opportunity of making
group income elections in respect of such dividends.
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