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Non-discrimination and group income elections

|Treaty Development|United Kingdom-Japan-United States
United Kingdom-Japan-United States

On 23 May 2007, the House of Lords gave judgment in the case of Boake Allen Ltd v. HMRC [2007] UKHL 25 concerning the group litigation order (GLO) claiming that a group comprising a UK resident subsidiary and a parent company resident outside the European Union is entitled to compensation for having had to pay Advance Corporation Tax (ACT) on UK dividends that could have been avoide…

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