In GKN, the taxpayer successfully obtained a substantial interim payment in the FII GLO. David Pickstone thinks that the FII group may not be the only taxpayers affected by that decision.
GKN Holdings is the latest in a long line of hearings relating to the franked investment income group litigation (FII GLO). After the disappointment of the Court of Appeal’s decision in 2010 ([2010] EWCA Civ 103) the claimants will have been cheered by the recent decisions of the Supreme Court ([2012] UKSC 19]) and CJEU (C-35/11).
While things certainly seem to be going in the taxpayers’ direction there are still a number of questions which need to be answered and it will no doubt take a number of years to answer them. The Supreme Court has made yet another reference to the CJEU...
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